
MEMORANDUM

TO:	Andrew Bouchard and Brenda Shine, EPA

FROM:	Mae Thomas, Jason Renzaglia, and Philip Crawford, ERG

DATE:	January 20, 2012

SUBJECT: 	Comparison of Reporting Burden between Hardcopy Reports Submitted under Existing Rules and Semiannual Electronic Reports Submitted for Uniform Standards
--------------------------------------------------------------------------------

INTRODUCTION
      All semiannual reporting elements are required to be submitted electronically by the proposed Uniform Standards; this is expected to result in significant cost savings and burden reductions for industry and regulatory agencies. In addition, some data elements previously required to be reported semiannually are proposed to be submitted annually in the Uniform Standards. This memorandum describes the methods and procedures used to estimate the burden as a result of complying with the proposed Uniform Standards semiannual electronic reporting requirements and annual written reporting requirements compared to entirely written reporting requirements in existing rules. This analysis considered routine reporting burden and did not include initial reports (such as the Notification of Compliance Status reports) or reports required in unique situations (such as request for a performance test waiver). 
      Burden reductions were estimated for two model facilities: a refinery and a chemical plant. These models were selected to provide an estimate of the costs for facilities that are considered typical in size, as well as number and types of applicable rules. This memorandum provides a comparison of burden under existing rules and the proposed Uniform Standards for each model facility. This memorandum also provides a description of each model facility, identifies all applicable regulations and related supporting statements, and describes the specific methodology for estimating the burden reduction. 
      This memorandum is organized as follows:
      1.0	Introduction
      2.0	Results
      3.0	Model Facility Descriptions
      4.0	Methodology
      5.0 	References
      Appendix A:  Model Facility Descriptions: Rule Applicability
      Appendix B:  Burden Estimation and Supporting Statement Analysis  -  Model Refinery
      Appendix C:  Burden Estimation and Supporting Statement Analysis  -  Model Chemical Plant
      Appendix D:  Electronic Reporting Cost Analysis
Results
      For each model facility, the burden was estimated for complying with the proposed Uniform Standards electronic reporting requirements and compared to the burden associated with written reporting requirements in existing rules. It was assumed that the cost of record keeping would not change from existing rules to the proposed Uniform Standards for each model facility. Table 1 presents the total reporting costs under existing rules, the proposed Uniform Standards, and the potential savings for the model facilities. The model chemical plant is smaller than the model refinery plant which generally explains the difference in the burden estimates.
Table 1. Reporting Burden Comparison for Hardcopy and Electronic Reporting under the Proposed Uniform Standards for a Model Refinery and Model Chemical Plant
                               Reporting Scheme
                          Model Refinery Annual Cost
                                    ($/yr)
                    Model Chemical Plant Annual Cost ($/yr)
                                Existing Rules 
                                    52,847
                                    16,014
                          Proposed Uniform Standards 
                                   21,409[1]
                                   9,235[1]
                                 Total Savings
                                    31,438
                                     6,779
                               Total Savings (%)
                                      59%
                                      42%
              1  -  An initial electronic startup cost of $5,333 was calculated for the model refinery and 
              $2,685 for the model chemical plant; these costs are expected to be incurred by each model
              facility for the first year of compliance with the proposed Uniform Standards. The initial 
              electronic startup cost is not included in the proposed Uniform Standards annual costs shown. 
Model Facility Descriptions
      Two model facilities were developed for the burden reduction estimate: a refinery and a chemical plant. Each model is representative of typical medium sized facilities currently operating in the United States. The following section briefly describes each model facility type. 
Refinery

      The model refinery was created using issued Title V air permits for existing refineries. Information regarding process units, emission points, and federal rule applicability were extracted from the technical documentation for the Title V permits. The process units associated with existing refineries were compared against the process units at other refineries in the United States using the published list of refineries and process characteristics provided in the Oil and Gas Journal (Oil & Gas, 2000). This comparison ensured that the model refinery was a typical sized facility in regards to process unit counts. For example, although one of the existing refineries operates more than one pipe still, only one pipe still was included in the model refinery to reflect a capacity (i.e., 200,000 barrels per day) more typical of refineries located in the United States. Table 2 lists the number and type of process units included in the model refinery. 
Table 2. Number and Type of Process and Emission Points Included for Model Refinery
                                 Process Unit
                                Number of Units
Oil Movements
                                       1
Pipe Stills
                                       1
Sulfur Recovery Unit
                                       1
Alkylation Unit
                                       1
Isomerization Unit
                                       1
Naptha Stream Treatment Plants
                                       2
Ultraformers
                                       2
Hydrogen Unit
                                       1
Cat Feed Hydrotreating
                                       1
Catalytic Refining
                                       1
Fluidized Catalytic Cracking
                                       1
Marine Dock Facility
                                       1
Marketing Terminal
                                       1
                                Emission Point
                                       
Process Vents
                                       7
Equipment Leaks (Process Units)
                                      16
Transfer Operations
                                       2
External Floating Roof Storage Vessel
                                      37
Internal Floating Roof Storage Vessel
                                      11
      
      
Chemical Plant

      The model chemical plant was created using issued Title V air permits for existing chemical plants. Information regarding process units, emission points, and federal rule applicability was extracted from technical documents for the Title V permits. Table 3 lists the number and type of process units included in the model chemical plant. 
Table 3. Number and Type of Process and Emission Points Included for Model Chemical Plant
                                 Process Unit
                                Number of Units
Phenol Production
                                       1
Resin Production
                                       1
Polymer Production
                                       1
                                Emission Point
                                       
Process Vents
                                      14
Equipment Leaks (Process Units)
                                       3
Transfer Operations
                                       7
Storage Vessels
                                      20
      
methodology
      A similar methodology was used for both model facilities to develop the burden estimates for the existing regulations and reporting burden for the proposed Uniform Standards. All applicable federal regulations pertaining to each model facility were identified (see Section 4.1). Supporting statements for each applicable rule were gathered and used to estimate the annual record keeping and reporting burden for each model facility under existing requirements (see Section 4.2). The potential reporting cost savings associated with the proposed Uniform Standards (not considering initial electronic startup costs) were estimated by comparing reporting costs associated with the Uniform Standards  to the reporting cost under existing requirements (see Section 4.3). The following sections provide specific details regarding each model facility and the burden reduction and cost estimation methodology. 
Applicable Rules
      After developing each model facility, the first step in estimating the cost savings consisted of identifying all applicable existing federal regulations for each model. Overlap of existing applicable rules was considered. For example, 40 CFR 63.640(p) indicates that if an owner or operator is subject to both Subpart CC and an equipment leak rule in 40 CFR 60 and/or 40 CFR 61, the owner or operator need only comply with Subpart CC. The details of overlapping existing rules are identified in the footnotes to Table 4 and Table 5 of this section. Wastewater regulations were not considered because, at the time of this analysis, the Uniform Standards did not include wastewater requirements.
Refinery
      Table 4 lists the federal regulations applicable to the model refinery, organized by emission type. Appendix A provides detail of each process unit and emission point and the corresponding regulation.  
      Table 4. Applicable Regulations by Emission Type  -  Model Refinery
                                 Emission Type
                             Applicable Regulation
                                 Process Vents
                          40 CFR Part 63, Subpart CC
                                       
                          40 CFR Part 63, Subpart UUU
                                Equipment Leaks
                          40 CFR Part 63, Subpart CC
                                       
                         40 CFR Part 61, Subpart V[1]
                                       
                         40 CFR Part 60, Subpart VV[2]
                              Transfer Operations
                         40 CFR Part 63, Subpart CC[3]
                                       
                          40 CFR Part 60, Subpart XX
                                       
                           40 CFR Part 63, Subpart Y
                                       
                           40 CFR Part 63, Subpart R
                                Storage Vessels
                          40 CFR Part 63, Subpart CC

                         40 CFR Part 63, Subpart G[4]

                           40 CFR Part 60, Subpart K

                          40 CFR Part 60, Subpart Ka

                          40 CFR Part 60, Subpart Kb
1  -  40 CFR Part 61, Subpart J points to 40 CFR Part 61, Subpart V.
2  -  40 CFR Part 60, Subpart GGG points to 40 CFR Part 60, Subpart VV.
3  -  40 CFR Part 63, Subpart CC indicates that if 40 CFR Part 60, Subpart XX applies, the model refinery must comply with 40 CFR Part 63, Subpart CC.
4  -  40 CFR Part 63, Subpart CC requires refineries comply with 40 CFR Part 63, Subpart G. 

Chemical Plant
      Table 5 lists the federal regulations applicable to the model chemical plant, organized by emission type. Appendix A provides detail of each process unit and emission point and the corresponding regulation.
      Table 5. Applicable Regulations by Emission Type  -  Model Chemical Plant
                                 Emission Type
                             Applicable Regulation
                                 Process Vents
                        40 CFR Part 60, Subpart NNN[1]
                                       
                         40 CFR Part 63, Subpart SS[2]
                                       
                           40 CFR Part 63, Subpart G
                                       
                         40 CFR Part 63, Subpart FFFF
                                Equipment Leaks
                         40 CFR Part 63, Subpart TT[3]
                                       
                        40 CFR Part 63, Subpart H[4,5]
                                       
                         40 CFR Part 63, Subpart I[5]
                                       
                         40 CFR Part 63, Subpart FFFF
                              Transfer Operations
                           40 CFR Part 63, Subpart G
                                       
                         40 CFR Part 63, Subpart FFFF
                                Storage Vessels
                           40 CFR Part 63, Subpart G

                         40 CFR Part 63, Subpart FFFF

                          40 CFR Part 63, Subpart SS

                          40 CFR Part 60, Subpart Kb
1  -  The process tank vent is subject to 40 CFR Part 60, Subpart RRR; however, pursuant to 40 CFR 60.700(c)(5), the vent complies with 40 CFR Part 60, Subpart NNN.
2  -  Pursuant to 40 CFR Part 63, Subpart YY, it was assumed that the TRE is below 4.0 for two vent gas absorbers and the model facility must comply with 40 CFR 63, Subpart SS.
3  -  Pursuant to 40 CFR Part 63, Subpart YY, it was assumed that the model chemical plant has chosen to comply with the requirements of 40 CFR 63, Subpart TT, instead of the requirements of 40 CFR 63, Subpart UU. 
4  -  It was assumed that the model chemical plant has elected to comply with 40 CFR Part 63, subpart H for all equipment in this process unit. Compliance with the provisions of 40 CFR 63, Subpart H, shall be deemed to constitute compliance with 40 CFR part 60, subpart VV.
5  -  Equipment in methylene chloride service located in a process producing polycarbonates are regulated under 40 CFR 63, Subpart H and I instead of 40 CFR 63, Subpart YY.
Determination of Burden Under Existing Rules
      After identifying all federal regulations applicable to the model facilities, supporting statements were collected from the EPA "Information Collection Request, Review, and Approval System" (ICRAS) system and rule making dockets. Supporting statements provide a detailed estimation of the respondent burden and costs as a result of demonstrating compliance through testing, monitoring, record keeping, and reporting with a particular regulation. Supporting statements generally provide burden estimates for the first three years in which affected sources must demonstrate compliance.  
      Each supporting statement generally contains standardized respondent burden and cost algorithms. These algorithms identify each burden item (e.g., reading instructions for reporting requirements, conducting performance tests or equipment leak monitoring, creating a periodic report, maintain records, etc.) and an associated estimate of the hourly requirement for each occurrence of the burden item. The algorithm typically contains an estimate of the number of occurrences, per year, for each burden item, and the number of respondents per year. The algorithms generally multiply the hourly requirement per burden item by the number of occurrences per year, and by the number of respondents per year to obtain a technical personnel hourly requirement for all affected sources on an annual basis. Managerial and clerical hours are usually obtained by multiplying the annual technical hourly requirement by standardized factors. Managerial and clerical hours were assumed to be five and ten percent of the annual technical hourly requirement, respectively. The annual hourly requirements for each labor category (i.e., technical, managerial, and clerical) are multiplied by standardized labor rates to obtain an annual cost for all sources affected by the regulation.  
      Although supporting statements are relatively consistent with regards to methodology, the accounting for the number of occurrences per respondent and respondents per year varies from rule to rule. For example, for certain regulations, the supporting statement algorithm may estimate the hourly requirement for a particular emission point as equivalent for all affected sources (i.e., the number of respondents per year for a performance test for one supporting statement might be equal to the number of affected sources) whereas another supporting statement may account for each individual process vent at all affected sources when estimating the number of respondents per year. 
      To develop an annual burden estimate for each model facility, supporting statements for all applicable regulations were carefully reviewed to identify how the number of occurrences per respondent and respondents per year were determined. The same determination processes were then applied to each model facility to estimate the annual hourly burden for record keeping and reporting under existing rules. Additionally, any initial or "one-time" burden items were ignored since the model facilities were assumed to be existing sources and already in compliance with any initial or "one-time" burden items.
      After determining annual hourly burdens for each model facility, the hourly requirements were multiplied by standardized labor rates to obtain annual record keeping and reporting costs. Labor rates were based on U.S. Department of Labor, Bureau of Labor Statistics labor rates (DOL, 2009). A fringe benefit loading rate of 1.5 and an overhead and profit rate of 1.4 were multiplied by each hourly rate to obtain loaded rates. Calculated hourly labor rates are presented in Table 6. 
                  Table 6. Summary of 2009 Hourly Labor Rates
                                  Labor Class
                                     (A) 
                       Mean hourly labor rate[1] ($/hr)
                                     (B) 
                          Fringe benefit loading rate
                         (C) Overhead and profit rate
                       (D=AxBxC) Loaded wage rate ($/hr)
           Professional Specialty and Technical (SOC Code: 17-2081)
                                     39.53
                                      1.5
                                      1.4
                                     83.01
         Executive, Administrative and Managerial (SOC Code: 11-9041)
                                     57.8
                                      1.5
                                      1.4
                                    121.38
        Administrative Support, Including Clerical (SOC Code: 43-0000)
                                     17.31
                                      1.5
                                      1.4
                                     36.35
      
      Appendices B and C contain detailed analyses of each supporting statement algorithm along with any assumptions associated with each model facility burden estimates.
Determination of Uniform Standards Reporting Costs
      In an effort to reduce the record keeping and reporting burden for industry and regulatory agencies, the proposed Uniform Standards require some electronic reporting in lieu of more traditional hardcopy methods. In particular, reports proposed to be submitted electronically in the Uniform Standards include all performance test reports, CEMS performance evaluation reports, the 40 CFR part 65, subparts I and J portions of the notification of compliance status reports required by 40 CFR part 65, subparts I and J, and semiannual periodic reports specified in 40 CFR part 65, subparts H, I, J, and M. All other reports would be submitted in hardcopy or other method mutually agreed to between the source and the delegated authority. The potential reporting cost savings associated with the proposed Uniform Standards (not considering initial electronic startup costs) were estimated for each model facility by comparing reporting costs associated with the Uniform Standards to the reporting costs estimated for existing regulations.
Determination of Initial Electronic Reporting Costs
      Initial costs of electronic reporting were estimated for each facility by first estimating the number of data elements included in the initial setup for electronic reporting for the model facility. It was assumed that sources will need to enter information about their facility that will include general information about their processes, emission units subject to rules, and basic information about the rules that apply. For example, in addition to general identification information for the facility, the following data elements were expected to be required for the initial transfer operations setup:  control type, the control equipment identification, the type of material transferred, the capacity of the transfer system, and the annual average of actual material loaded. In addition, five miscellaneous data elements were also added to the count of data elements due to unknown requirements of the electronic reporting program. Since sources will have to report similar information under multiple rules, the number of applicable regulations was then added to the count of data elements. The number of applicable regulations was not multiplied by the data element count because sources are expected to be able to simply assign the data elements to multiple rules instead of completely re-entering each data element.
      The total count of data elements (including the number of applicable regulations) for each emission source type was multiplied by the number of emission sources at each model facility. In the case of transfer operations at the model refinery, ten data elements were added to four applicable rules for a total of fourteen entries. The fourteen entries were then multiplied by two transfer operations (e.g., two transfer operations exist at the model refinery) for a total of twenty-eight data entry elements for transfer operations at the model refinery. The total number of data entry elements for each emission source was then divided by a factor of twenty-five data elements entered per hour. This hourly requirement was regarded as the initial technical hourly requirement for electronic reporting. 
      Using this methodology, the initial hourly requirements for electronic reporting startup were determined for each model facility and emission source type; these are presented in Appendix D. The managerial and clerical hours were obtained by using the same standardized factors described in section 4.2. Initial costs were obtained by multiplying the hourly requirements by the hourly labor rates presented in Table 6 in section 4.2 and are presented in Appendix D.
Determination of Annual Electronic Reporting Costs
      Annual costs of electronic reporting under the Uniform Standards were estimated in a fashion similar to the initial costs of electronic reporting. For simplicity, annual and semiannual reporting costs were first estimated as if all existing written reporting were converted to electronic reporting. All data elements that would be required to be reported on an annual or semiannual basis by the proposed Uniform Standards were identified and categorized as such. Then, using equipment counts and other information about the model facility, the number of data elements to be entered per year into the electronic reporting program was identified. The total number of data entry records to be entered into the electronic reporting program was divided by a factor of twenty-five data elements entered per hour. This hourly requirement was regarded as the annual technical hourly requirement for electronic reporting. Managerial and clerical hours, and the costs associated with those hourly requirements, were determined in the same manner as the initial costs. The cost associated with the additional requirement in the Uniform Standards to semiannually electronically report daily and operating block averages was computed by assuming 1 hour per process vent to upload data entered twice a year. 
      In order to get a total annual cost associated with electronic semiannual and written annual reports, the portion of costs associated with electronic annual reporting was converted to costs associated with written annual reporting using a ratio. The ratio was computed by dividing the costs associated with written reporting under existing rules by the sum of the Uniform Standards costs associated with semiannual periodic electronic reports and two times the costs associated with annual periodic electronic reports. The annual costs were multiplied by two because, under most existing rules, these reporting elements are required to be submitted semiannually. This ratio represents a conversion factor between electronic and written reporting burden. Finally, the potential reporting cost savings associated with the proposed Uniform Standards was determined by subtracting the total costs associated with electronic semiannual and written annual reports, from the total annual cost associated with written reporting under existing rules (see Section 4.2 for determination of burden under existing rules).
      The annual electronic reporting cost analysis as described here is presented in Appendix D to this document.

References

U.S. Department of Labor Bureau of Labor Statistics (DOL). 2009. Occupational employment statistics: May 2009 Employment wage estimates. <http://stats.bls.gov/oes/current/oessrci.htm>. November. 
    
Stell, J. 2000. U.S. Refineries-State Capacities as of January 1, 2001. Oil & Gas Journal. 99:52.  

Information Collection Request (ICR) Supporting Statements:
         a.          The Consolidated Air Rule (CAR) for the Synthetic Organic Chemical Manufacturing Industry (SOCMI) (Renewal). 2010. EPA ICR Number 1854.07, OMB Control Number 2060-0443. 
         b.          National Emission Standards for Hazardous Air Pollutants for Gasoline Distribution Facilities (40 CFR Part 63, Subpart R) (Renewal). 2010. EPA ICR Number 1659.07, OMB Control Number 2060-0325. 
         c.          National Emission Standards for Hazardous Air Pollutants for Marine Tank Vessel Loading Operations (40 CFR Part 63, Subpart Y). 2010. EPA ICR Number 1679.08. 
         d.          National Emission Standards for Hazardous Air Pollutants for Petroleum Refineries (40 CFR Part 63, Subpart CC) (Renewal). 2009. EPA ICR Number 1692.06, OMB Control Number 2060-0340. 
         e.          National Emission Standards for Hazardous Air Pollutants for Source Categories: Generic Maximum Achievable Control Technology Standards (40 CFR part 63, subpart YY) (Renewal). 2009. EPA ICR Number 1871.05, OMB Control Number 2060-0420. 
         f.          National Emission Standards for Hazardous Air Pollutants for Petroleum Refineries, Catalytic Cracking, Reforming and Sulfur Units (40 CFR Part 63, Subpart UUU) (Renewal). 2009. EPA ICR Number 1844.04, OMB Control Number 2060-0554. 
         g.          National Emission Standards for Hazardous Air Pollutants for Miscellaneous Organic Chemical Manufacturing (40 CFR part 63, subpart FFFF) (Renewal). 2010. EPA ICR Number 1969.04. 
         h.          New Source Performance Standards for Storage Vessels for Petroleum Liquids for which Construction, Reconstruction or Modification Commenced After June 11, 1973, and Prior to May 19, 1978 (40 CFR Part 60, Subpart K) (Renewal). 2010. EPA ICR Number 1797.05, OMB Control Number 2060-0442. 
         i.          New Source Performance Standards for Bulk Gasoline Terminals (40 CFR Part 60, Subpart XX) (Renewal). 2008. EPA ICR Number 0664.09, OMB Control Number 2060-0006. 
         j.          New Source Performance Standards for Equipment Leaks of VOC in Petroleum Refineries (40 CFR Part 60, Subpart GGG and GGGa) (Renewal). 2011. EPA ICR Number 0983.12, OMB Control Number 2060-0067. 

                                  Appendix A:
                                       
                         Model Facility Descriptions:
                                       
                              Rule Applicability
Table A.1 Model Refinery  -  Rule Applicability Table for Process Vents, Equipment Leaks, and Transfer Operations
                              Process Description
                                 Process Vent
                                Equipment Leaks
                              Transfer Operations

     40 CFR Part 63, Subpart CC 
Petroleum Refineries (process vents)[[1]]
40 CFR Part 63, Subpart UUU 
Catalytic Cracking Units, Catalytic Reforming Units, and Sulfur Recovery Units 
      40 CFR Part 63, Subpart CC 
Petroleum Refineries (equipment leaks)
40 CFR Part 61 Subpart J points to
40 CFR Part 61 Subpart V
Equipment Leaks (Fugitive Emission Sources)
40 CFR Part 60, Subpart GGG points to
40 CFR Part 60, Subpart VV
Equipment Leaks of VOC in the SOCMI
  40 CFR Part 63, Subpart CC 
Petroleum Refineries (transfer operations)[[2]]
              40 CFR Part 60, Subpart XX 
Bulk Gasoline Terminals
       40 CFR Part 63, Subpart Y 
Marine Tank Vessel Loading Operations
          40 CFR Part 63, Subpart R 
Gasoline Distribution Facilities
1 and 2 Pipe Stills
                                       
                                       
                                       x
                                       
                                       x
                                       
                                       
                                       
                                       
Sulfur Recovery Unit
                                       
                                       x
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Alkylation Unit 
                                       x
                                       
                                       x
                                       
                                       x
                                       
                                       
                                       
                                       
Isomerization Unit 
                                       x
                                       
                                       x
                                       
                                       x
                                       
                                       
                                       
                                       
No.2 Treatment Plant 
                                       
                                       
                                       x
                                       
                                       x
                                       
                                       
                                       
                                       
No.4 Treatment Plant 
                                       
                                       
                                       x
                                       
                                       x
                                       
                                       
                                       
                                       
Storage and Loading Facilities 
                                       
                                       
                                       x
                                       
                                       x
                                       
                                       
                                       
                                       
No.3 Ultraformer 
                                       x
                                       x
                                       x
                                       
                                       x
                                       
                                       
                                       
                                       
No.4 Ultraformer 
                                       
                                       x
                                       x
                                       
                                       x
                                       
                                       
                                       
                                       
Hydrogen Unit 
                                       
                                       
                                       x
                                       
                                       x
                                       
                                       
                                       
                                       
Cat Feed Hydrotreating 
                                       
                                       
                                       x
                                       
                                       x
                                       
                                       
                                       
                                       
Catalytic Refining 
                                       
                                       
                                       x
                                       x
                                       x
                                       
                                       
                                       
                                       
Fluidized Catalytic Cracking 
                                       
                                       x
                                       x
                                       
                                       x
                                       
                                       
                                       
                                       
Oil Movements 
                                       
                                       
                                       x
                                       x
                                       x
                                       
                                       
                                       
                                       
Marketing Terminal
                                       
                                       
                                       
                                       
                                       
                                       x
                                       x
                                       
                                       x
Marine Dock Facility
                                       
                                       
                                       x
                                       x
                                       x
                                       x
                                       
                                       x
                                       
Vapor Recovery 1
                                       
                                       
                                       x
                                       
                                       x
                                       
                                       
                                       
                                       
Vapor Recovery 2
                                       x
                                       
                                       x
                                       
                                       x
                                       
                                       
                                       
                                       
                                                                          TOTAL
                                       4
                                       4
                                      16
                                       3
                                      16
                                       2
                                       1
                                       1
                                       1
[1] Alkylation Unit: off gas knock out drum (D-3) controlled by a flare (F-27); spent acid stripper drum (D-4) controlled by a flare (F-27); and spent caustic drum (D-5) controlled by a flare (F-27). Isomerization Unit: flare knock out drum (D-1) controlled by a flare (F-2). No.3 Ultraformer: flare gas separator (D-1) controlled by a flare (F-2). Vapor Recovery Unit 300: off-gas knock out drum (D-2) controlled by a flare (F-3).
[2] Subpart CC says that if Subparts XX and/or QQQ apply, comply with Subpart CC.
   Table A.2 Model Refinery  -  Rule Applicability Table for Storage Vessels
                          Storage Vessel Description
                                     Rule
                                   Tank ID #
                                Year Installed
                                     Size
                               Control Required?
                                 Control[[1]]
                                  Liquid Type
                                Vapor Pressure
                          40 CFR Part 63, Subpart CC
                           40 CFR Part 63, Subpart G
                           40 CFR Part 60, Subpart K
                          40 CFR Part 60, Subpart Ka
                          40 CFR Part 60, Subpart Kb
3486
1979
4,026,505
Y
EFR
petroleum hydrocarbon
<15 psia
                                       x
                                       x
                                       
                                       x
                                       
3511
1973
4,066,214
Y
EFR
petroleum hydrocarbon
<15 psia
                                       x
                                       x
                                       x
                                       
                                       
3532
1953
868,306
Y
EFR
petroleum hydrocarbon
<15 psia
                                       x
                                       x
                                       
                                       
                                       
3533
1953
4,235,640
Y
EFR
petroleum hydrocarbon
<15 psia
                                       x
                                       x
                                       
                                       
                                       
3601
1977
3,702,020
Y
EFR
petroleum hydrocarbon
<15 psia
                                       x
                                       x
                                       x
                                       
                                       
3909
1956
3,388,512
Y
EFR
petroleum hydrocarbon
<15 psia
                                       x
                                       x
                                       
                                       
                                       
3915
1980
6,353,460
Y
EFR
petroleum hydrocarbon
<15 psia
                                       x
                                       x
                                       
                                       x
                                       
3917
1980
25,413,839
Y
EFR
petroleum hydrocarbon
<15 psia
                                       x
                                       x
                                       
                                       x
                                       
3534
1955/1973
71,000
Y
EFR
petroleum hydrocarbon
<15 psia
                                       
                                       
                                       x
                                       
                                       
3537
1962/1974
56,000
Y
EFR
petroleum hydrocarbon
<15 psia
                                       
                                       
                                       x
                                       
                                       
3605
1977
3,702,000
Y
EFR
petroleum hydrocarbon
<15 psia
                                       
                                       
                                       x
                                       
                                       
3480
1982
4,026,505
Y
IFR
petroleum hydrocarbon
<15 psia
                                       
                                       
                                       
                                       x
                                       
3487
1980
4,026,505
Y
IFR
petroleum hydrocarbon
<15 psia
                                       
                                       
                                       
                                       x
                                       
3525
1981
4,026,505
Y
IFR
petroleum hydrocarbon
<15 psia
                                       
                                       
                                       
                                       x
                                       
3526
1943/1979
4,026,505
Y
IFR
petroleum hydrocarbon
<15 psia
                                       
                                       
                                       
                                       x
                                       
3553
1981
5,070,343
Y
IFR
petroleum hydrocarbon
<15 psia
                                       
                                       
                                       
                                       x
                                       
3554
1981
5,070,343
Y
IFR
petroleum hydrocarbon
<15 psia
                                       
                                       
                                       
                                       x
                                       
3602
1979
3,856,271
Y
IFR
petroleum hydrocarbon
<15 psia
                                       
                                       
                                       
                                       x
                                       
3604
1980
3,856,271
Y
IFR
petroleum hydrocarbon
<15 psia
                                       
                                       
                                       
                                       x
                                       
3702
1943/1982/1997
3,382,264
Y
IFR
petroleum hydrocarbon
<15 psia
                                       
                                       
                                       
                                       x
                                       
3703
1944/1982
3,382,264
Y
IFR
petroleum hydrocarbon
<15 psia
                                       
                                       
                                       
                                       x
                                       
3704
1944/1980
3,382,264
Y
IFR
petroleum hydrocarbon
<15 psia
                                       
                                       
                                       
                                       x
                                       
3916
1980
13,666,998
Y
EFR
petroleum hydrocarbon
<15 psia
                                       
                                       
                                       
                                       x
                                       
3918
1980
13,666,998
Y
EFR
petroleum hydrocarbon
<15 psia
                                       
                                       
                                       
                                       x
                                       
3919
1980
13,666,998
Y
EFR
petroleum hydrocarbon
<15 psia
                                       
                                       
                                       
                                       x
                                       

Table A.2 Model Refinery  -  Rule Applicability Table for Storage Vessels (Cont.)
                          Storage Vessel Description
                                     Rule
                                   Tank ID #
                                Year Installed
                                     Size
                               Control Required?
                                    Control
                                  Liquid Type
                                Vapor Pressure
                          40 CFR Part 63, Subpart CC
                           40 CFR Part 63, Subpart G
                           40 CFR Part 60, Subpart K
                          40 CFR Part 60, Subpart Ka
                          40 CFR Part 60, Subpart Kb
3920
1980
13,666,998
Y
EFR
petroleum hydrocarbon
<15 psia
                                       
                                       
                                       
                                       x
                                       
3474
1992
3,734,422
Y
EFR
petroleum hydrocarbon
<15 psia
                                       
                                       
                                       
                                       
                                       x
3475
1994
3,865,445
Y
EFR
petroleum hydrocarbon
<15 psia
                                       
                                       
                                       
                                       
                                       x
3476
1984
3,085,016
Y
EFR
petroleum hydrocarbon
<15 psia
                                       
                                       
                                       
                                       
                                       x
3484
1996
3,865,445
Y
EFR
petroleum hydrocarbon
<15 psia
                                       
                                       
                                       
                                       
                                       x
3488
1994
3,865,445
Y
EFR
petroleum hydrocarbon
<15 psia
                                       
                                       
                                       
                                       
                                       x
3489
1996
3,865,445
Y
EFR
petroleum hydrocarbon
<15 psia
                                       
                                       
                                       
                                       
                                       x
3493
1995
3,865,445
Y
EFR
petroleum hydrocarbon
<15 psia
                                       
                                       
                                       
                                       
                                       x
3514
1984
4,066,214
Y
EFR
petroleum hydrocarbon
<15 psia
                                       
                                       
                                       
                                       
                                       x
3527
1991
3,382,264
Y
EFR
petroleum hydrocarbon
<15 psia
                                       
                                       
                                       
                                       
                                       x
3528
1993
3,865,445
Y
EFR
petroleum hydrocarbon
<15 psia
                                       
                                       
                                       
                                       
                                       x
3549
1993
588,283
Y
EFR
petroleum hydrocarbon
<15 psia
                                       
                                       
                                       
                                       
                                       x
3558
1972/1986
376,501
Y
EFR
petroleum hydrocarbon
<15 psia
                                       
                                       
                                       
                                       
                                       x
3600
1993
847,128
Y
EFR
petroleum hydrocarbon
<15 psia
                                       
                                       
                                       
                                       
                                       x
3622
1993
3,865,445
Y
EFR
petroleum hydrocarbon
<15 psia
                                       
                                       
                                       
                                       
                                       x
3629
1992
3,865,445
Y
EFR
petroleum hydrocarbon
<15 psia
                                       
                                       
                                       
                                       
                                       x
3701
1943/1993
3,382,264
Y
EFR
petroleum hydrocarbon
<15 psia
                                       
                                       
                                       
                                       
                                       x
3715
1945/1987/1998
3,382,264
Y
EFR
petroleum hydrocarbon
<15 psia
                                       
                                       
                                       
                                       
                                       x
3716
1996
3,865,445
Y
EFR
petroleum hydrocarbon
<15 psia
                                       
                                       
                                       
                                       
                                       x
3860
1993
211,782
Y
EFR
petroleum hydrocarbon
<15 psia
                                       
                                       
                                       
                                       
                                       x
3904
1956/1986
3,388,512
Y
EFR
petroleum hydrocarbon
<15 psia
                                       
                                       
                                       
                                       
                                       x
3907
1956/1996
3,388,512
Y
EFR
petroleum hydrocarbon
<15 psia
                                       
                                       
                                       
                                       
                                       x
3911
1956/1986
3,388,512
Y
EFR
petroleum hydrocarbon
<15 psia
                                       
                                       
                                       
                                       
                                       x
TOTAL
                                       8
                                       8
                                       5
                                      18
                                      22
[1] EFR - External Floating Roof; IFR - Internal Floating Roof



















Table A.3 Model Chemical Plant  -  Rule Applicability for Process Vents, Equipment Leaks, and Transfer Operations
                              Process Description
                                 Process Vent
                                Equipment Leaks
                              Transfer Operations

                         40 CFR Part 60, Subpart NNN 
                           40 CFR Part 63 Subpart SS
                           40 CFR Part 63 Subpart G
                          40 CFR Part 63 Subpart FFFF
                           40 CFR Part 63 Subpart TT
                           40 CFR Part 63 Subpart H
                           40 CFR Part 63 Subpart I
                          40 CFR Part 63 Subpart FFFF
                           40 CFR Part 63 Subpart G
                          40 CFR Part 63 Subpart FFFF
Distillation (process with scrubber)
                                       x
                                       
                                     x[1]
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Process Tank Vent (routed to distillation)
                                     x[2]
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Detoxification Knockout Drum (with thermal catalytic control)
                                       
                                       
                                     x[3]
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Oxidate Vent Chiller Condenser
                                       
                                       
                                     x[1]
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Column Vent Chiller Condenser
                                       
                                       
                                     x[1]
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Air Oxidation Vent to Carbon Adsorbers
                                       
                                       
                                     x[1]
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Resin Vent Gas Absorber #1
                                       
                                     x[4]
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Resin Vent Gas Absorber #2
                                       
                                     x[4]
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Process Vent Controlled by Catalytic Oxidizer
                                       
                                       
                                       
                                     x[3]
                                       
                                       
                                       
                                       
                                       
                                       
Vent Tank Condenser
                                       
                                       
                                       
                                     x[1]
                                       
                                       
                                       
                                       
                                       
                                       
Stripper Vent Condenser
                                       
                                       
                                       
                                     x[1]
                                       
                                       
                                       
                                       
                                       
                                       
Resin Reactor
                                       
                                       
                                       
                                     x[1]
                                       
                                       
                                       
                                       
                                       
                                       
Process Vent with Hydrogen Halide and Halogen HAP
                                       
                                       
                                       
                                     x[3]
                                       
                                       
                                       
                                       
                                       
                                       
Condenser Vent
                                       
                                       
                                       
                                     x[1]
                                       
                                       
                                       
                                       
                                       
                                       
Equipment in the Phenol plant
                                       
                                       
                                       
                                       
                                       
                                     x[5]
                                       
                                       x
                                       
                                       
Equipment in methylene chloride service located in the Resin area
                                       
                                       
                                       
                                       
                                       
                                     x[6]
                                     x[6]
                                       
                                       
                                       
Equipment in HAP service in Resin area
                                       
                                       
                                       
                                       
                                     x[7]
                                       
                                       
                                       
                                       
                                       
Equipment that produces polymer
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       x
                                       
                                       
Phenol Loading Operation
                                       
                                       
 
 
                                       
                                       
                                       
                                       
                                     x[8]
                                       
Phenol Rail Car Loading
                                       
                                       
 
 
                                       
                                       
                                       
                                       
                                     x[8]
                                       
Truck Loading Connection #1
                                       
                                       
 
 
                                       
                                       
                                       
                                       
                                       
                                     x[8]
Truck Loading Connection #2
                                       
                                       
 
 
                                       
                                       
                                       
                                       
                                       
                                     x[8]
Truck Loading Connection #3
                                       
                                       
 
 
                                       
                                       
                                       
                                       
                                       
                                     x[8]
Truck Loading Connection #4
                                       
                                       
 
 
                                       
                                       
                                       
                                       
                                       
                                     x[8]
Railcar Loading Arms
                                       
                                       
 
 
                                       
                                       
                                       
                                       
                                       
                                     x[8]

Table A.3 Model Chemical Plant  -  Rule Applicability for Process Vents, Equipment Leaks, and Transfer Operations (Cont.)
                              Process Description
                                 Process Vent
                                Equipment Leaks
                              Transfer Operations

                         40 CFR Part 60, Subpart NNN 
                           40 CFR Part 63 Subpart SS
                           40 CFR Part 63 Subpart G
                          40 CFR Part 63 Subpart FFFF
                           40 CFR Part 63 Subpart TT
                           40 CFR Part 63 Subpart H
                           40 CFR Part 63 Subpart I
                          40 CFR Part 63 Subpart FFFF
                           40 CFR Part 63 Subpart G
                          40 CFR Part 63 Subpart FFFF
                                                                          TOTAL
                                       2
                                       2
                                       5
                                       6
                                       1
                                       2
                                       1
                                       2
                                       1
                                       5
[1] - Group 2 process vent with recovery device.
[2] Process vent is subject to 40 CFR Part 60, Subpart RRR; however, pursuant to 40 CFR 60.700(c)(5), VOC emissions from the process tank vent, shall be considered in compliance with the provisions of Subpart RRR because the vent stream is routed to a distillation unit (C-1) subject to 40 CFR 60, Subpart NNN and has no other releases to the air except for a pressure relief valve.
[3] Group 1 process vent with control equipment.
[4] Process vent is subject to 40 CFR Part 63, Subpart YY; however, there are no applicable requirements (or standards) for process vents with TRE index values greater than 4.0. 
[5] Pursuant to 40 CFR 63.160(c), the chemical plant has elected to comply with 40 CFR Part 63, subpart H for all equipment in this process unit. All VOC's in the phenol operations shall be considered, for purposes of applicability and compliance with 40 CFR Part 63, subpart H, as if it were organic hazardous air pollutant. Compliance with the provisions of 40 CFR 63, Subpart H, shall be deemed to constitute compliance with 40 CFR part 60, subpart VV.
[6] Pursuant to 40 CFR 63.190(b)(4), Subpart I, these components are regulated under 40 CFR 63, Subpart H and I instead of 40 CFR 63, Subpart YY.
[7] 40 CFR Part 63 Subpart YY points to 40 CFR Part 63 Subparts TT and UU.  Pursuant to Table 5 of 40 CFR 63.1103(d), Subpart YY, the chemical plant has chosen to comply with the requirements of 40 CFR 63, Subpart TT, instead of the requirements of 40 CFR 63, Subpart UU. 
[8] Group 2 loading operation.

   Table A.4 Model Chemical Plant  -  Rule Applicability for Storage Vessels
                          Storage Vessel Description
                                     Rule
                                   Tank ID #
                                Year Installed
                                     Size
                                   Control 
                           40 CFR Part 63, Subpart G
                          40 CFR Part 63 Subpart FFFF
                           40 CRF Part 63 Subpart SS
                          40 CFR Part 60, Subpart Kb
Phenol Tank #1
                                  after 1984
                                  >=75m^3
                                      IFR
                                       
                                       
                                       
                                    x[[1]]
Phenol Tank #2
                                  after 1984
                                  >=75m^3
                                      EFR
                                       
                                       
                                       
                                    x[[1]]
Phenol Tank #3
                                       
                                       
                                       
                                    x[[2]]
                                       
                                       
                                       
Phenol Tank #4
                                       
                                       
                                       
                                    x[[2]]
                                       
                                       
                                       
Phenol Tank #5
                                       
                                       
                                       
                                    x[[2]]
                                       
                                       
                                       
Phenol Tank #6
                                       
                                       
                                       
                                    x[[2]]
                                       
                                       
                                       
Phenol Tank #7
                                       
                                       
                                       
                                    x[[2]]
                                       
                                       
                                       
Phenol Tank #8
                                       
                                       
                                       
                                    x[[2]]
                                       
                                       
                                       
Phenol Tank #9
                                       
                                       
                                      IFR
                                    x[[1]]
                                       
                                       
                                       
Phenol Tank #10
                                       
                                       
                                      EFR
                                    x[[1]]
                                       
                                       
                                       
Resin Tank #1
                                       
                               75<x<151m^3
                                       
                                       
                                       
                                    x[[3]]
                                       
Resin Tank #2
                                       
                               75<x<151m^3
                                       
                                       
                                       
                                    x[[3]]
                                       
Resin Tank #3
                                       
                               75<x<151m^3
                                       
                                       
                                       
                                    x[[3]]
                                       
Resin Tank #4
                                       
                               75<x<151m^3
                                       
                                       
                                       
                                    x[[3]]
                                       
Resin Tank #5
                                       
                               75<x<151m^3
                                       
                                       
                                       
                                    x[[3]]
                                       
Resin Tank #6
                                       
                               75<x<151m^3
                                       
                                       
                                       
                                    x[[3]]
                                       
Resin Tank #7
                                       
                                       
                                       
                                       
                                    x[[2]]
                                       
                                       
Resin Tank #8
                                       
                                       
                                       
                                       
                                    x[[2]]
                                       
                                       
Resin Tank #9
                                       
                                       
                                       
                                       
                                    x[[2]]
                                       
                                       
Resin Tank #10
                                       
                                       
                                       
                                       
                                    x[[2]]
                                       
                                       



                                                                          TOTAL
                                       8
                                       4
                                       6
                                       2
[1] Group 1 Process Tank (control required)


                                       
                                       
                                       
                                       
[2] Group 2 Process Tank (control required)


                                       
                                       
                                       
                                       
[3] In order to comply with 40 CFR 63, Subpart YY, pursuant to the control requirements of 40 CFR 63, Subpart SS, this chemical plant reduces HAP emissions by 95 weight percent by routing emissions from these tanks to the polycarbonate production process where methylene chloride is recovered and recycled.  No record keeping and reporting estimated for these tanks, since only initial records and reports are required.


                                  Appendix B:
                                       
    Burden Estimation and Supporting Statement Analysis  -  Model Refinery
 Table B.1 Model Refinery - Summary of Potential Cost Savings Associated with 
               Uniform Standard Electronic Semiannual Reporting
                                     RULE
                               (A) Recordkeeping
              (B) Reporting Under Existing Rules Via Paper Methods
(C) Reporting Under Proposed Uniform Standards with Electronic Elements Removed[[1]]
Part 63, Subpart CC
                                    $10,848
                                    $18,357
                                    $4,265
Part 60, Subpart K
                                     $834
                                      $0
                                      $0
Part 60, Subpart Ka
                                    $2,058
                                     $742
                                      $93
Part 60, Subpart Kb
                                    $12,331
                                    $22,029
                                      $0
Part 63, Subpart G
                                    $4,543
                                    $8,010
                                      $0
Part 60, Subpart VV
                                      $0
                                      $0
                                      $0
Part 61, Subpart V
                                      $0
                                      $0
                                      $0
Part 60, Subpart GGG
                                      $0
                                      $0
                                      $0
Part 63, Subpart R
                                    $17,152
                                    $1,854
                                      $0
Part 60, Subpart XX
                                      $0
                                      $0
                                      $0
Part 63, Subpart Y
                                     $116
                                      $0
                                      $0
Part 63, Subpart UUU
                                    $4,844
                                    $1,854
                                      $0
                                    Total 
                                    $52,726
                                    $52,847
                                    $4,358
                                       
(D) Initial Electronic Start-up Cost for Proposed Uniform Standards
                                    $5,333
(E) Cost of Semiannual Electronic Reporting for proposed Uniform Standards
                                    $4,992
(F) Cost of Annual Electronic Reporting for proposed Uniform Standards
                                    $1,502
(G) Written to Electronic Reporting Burden Ratio (G=B/(E+2F)) [[2]]
                                     6.61
(H) Administrative Preparation for Electronic Data Entry  -  management of log in information, etc.
                                     $834
(I) Additional Reporting Requirement in Uniform Standards - Cost to semiannually report daily and operating block averages, required in §65.882(e).[[3]]
                                    $1,298
(J) Proposed Uniform Standards Reporting Costs for Electronic Semiannual and Written Annual Reports (J=C+E+(F*G)+H+I) [[4]]
                                    $21,409
(K) Potential Reporting Cost Savings Not Considering Initial Electronic Startup Costs for Proposed Uniform Standards (K=B-J)
                                    $31,438
(L) Savings Percentage - Reporting Cost Basis (L=K/B*100)
                                      59%
(M) Savings Percentage - Record Keeping and Reporting Cost Basis (M=K/(A+B)*100)
                                      30%
[[1]] Certain reporting elements are not able to be transferred to the electronic cost such as reading and understanding the reporting requirements; therefore, costs for such items are retained.
[[2][]] Burden for annual reports multiplied by two because these are required semiannually under most existing rules. This ratio provides a general conversion between burden for electronic and written reports.
[[][3][]] Assumes 1 hour per process vent to upload data (7 process vents) entered twice a year for semiannual reporting for a total of 14 technical hours. Managerial and clerical hours were assumed to be five and ten percent of the annual technical hourly requirement, respectively.  Rates used are in Table 6 of memo.
[[4]] Annual reports are required in written format, therefore the burden associated with electronic annual reports was converted to burden for written reports (E*F).
                                       
Table B.2 Model Refinery  -  40 CFR Part 63, Subpart CC Supporting Statement Analysis [1]
                                  Burden item
                                      (A)
                                      (B)
                                      (C)
                                      (D)
                                      (E)
                                      (F)
                                      (G)
                                      (H)
                                      (I)
                                      (J)
                                       
        Person-hours per occurrence for SFI (from supporting statement)
    No. of occurrences per respondent per year (from supporting statement)
       Person-hours per respondent per year (from supporting statement)
           Person-hours per occurrence applicable to Model Refinery
              No. of occurrences for the Model Refinery per year
                 Person-hours for the Model Refinery per year
                            Technical Hours
(hr/yr)
                           Managerial Hours
(hr/yr)
                            Clerical Hours
(hr/yr)
  Total Cost ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr
                                       
                                       
                                       
                                    (C=AxB)
                                       
                                       
                                       
                                     (G=F)
                                  (H=G*0.05)
                                  (I=G*0.10)
                                       
1. Applications
                                      N/A
                                       
                                       
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                     0.0 
2. Survey and Studies
                                      N/A
                                       
                                       
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                     0.0 
3. Acquisition, Installation, and Utilization of Technology and Systems
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
4. Reporting Requirements
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
A. Read instructions and planning
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
  Initial:
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
    i. General/applicability 
                                      20
                                       1
                                      20
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                     0.0 
    ii. Storage vessels  
                                      20
                                       1
                                      20
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                     0.0 
    iii. Process units  - LDAR
                                      20
                                       1
                                      20
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                     0.0 
    iv. Process vents    
                                      20
                                       1
                                      20
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                     0.0 
  Periodic:
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
    i. General/applicability 
                                       4
                                       2
                                       8
                                       4
                                       2
                                       8
                                       8
                                      0.4
                                      0.8
                                    741.7 
    ii. Storage vessels  
                                       1
                                       2
                                       2
                                       1
                                       2
                                       2
                                       2
                                      0.1
                                      0.2
                                    185.4 
    iii. Process units  - LDAR 
                                       2
                                       2
                                       4
                                       2
                                       1
                                       4
                                       4
                                      0.2
                                      0.4
                                    370.9 
    iv. Process vents    
                                       2
                                       2
                                       4
                                       2
                                       2
                                       4
                                       4
                                      0.2
                                      0.4
                                    370.9 
B. Required activities
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
  Initial:
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
    i. General: applicability  
                                      10
                                       1
                                      10
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
                                     0.0 
    ii. Storage vessels  
                                      88
                                      0.9
                                     79.2
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
                                     0.0 
    iii. Process units  - LDAR 
                                       8
                                      1.1
                                      88
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
                                     0.0 
    iv. Process vents  - initial  performance test      
                                      11
                                      0.2
                                      22
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
                                     0.0 

Table B.2 Model Refinery  -  40 CFR Part 63, Subpart CC Supporting Statement Analysis (Cont.) [[1]]
                                  Burden item
                                      (A)
                                      (B)
                                      (C)
                                      (D)
                                      (E)
                                      (F)
                                      (G)
                                      (H)
                                      (I)
                                      (J)
                                       
        Person-hours per occurrence for SFI (from supporting statement)
    No. of occurrences per respondent per year (from supporting statement)
       Person-hours per respondent per year (from supporting statement)
           Person-hours per occurrence applicable to Model Refinery
              No. of occurrences for the Model Refinery per year
                 Person-hours for the Model Refinery per year
                            Technical Hours
(hr/yr)
                           Managerial Hours
(hr/yr)
                            Clerical Hours
(hr/yr)
  Total Cost ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr
                                       
                                       
                                       
                                    (C=AxB)
                                       
                                       
                                       
                                     (G=F)
                                  (H=G*0.05)
                                  (I=G*0.10)
                                       
    v. Process vents  -repeat  performance test              
                                      11
                                      0.1
                                      11
                                    0[[3]]
                                       0
                                       0
                                       0
                                       0
                                       0
                                     0.0 
Periodic
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
    i. General/applicability  
                                       3
                                       2
                                       6
                                       3
                                       2
                                       6
                                       6
                                      0.3
                                      0.6
                                    556.3 
    ii. Storage vessels  
                                       4
                                       9
                                      36
                                    0[[4]]
                                       0
                                       0
                                       0
                                       0
                                       0
                                     0.0 
    iii. Process units  - LDAR  
                                       
                                       
                                       
                                    1[[5]]
                                      16
                                      16
                                      16
                                      0.8
                                      1.6
                                   1,483.4 
    iv. Process vents    
                                       2
                                      24
                                      48
                                       2
                                    3[[6]]
                                       6
                                       6
                                      0.3
                                      0.6
                                    556.3 
C. Create information
                                    See 4B
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
D. Gather existing information
                                    See 4B
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
E. Write report  
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Startup, shutdown and malfunction plan  
                                      40
                                       1
                                      40
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                     0.0 
  Notification of compliance status                    
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
  i.  Storage vessels  
                                       1
                                      0.9
                                      0.9
                                  0[[][2][]]
                                       0
                                       0
                                       0
                                       0
                                       0
                                     0.0 
  ii. Process units  - LDAR 
                                       4
                                      1.1
                                      4.4
                                  0[[][2][]]
                                       0
                                       0
                                       0
                                       0
                                       0
                                     0.0 
  iii. Process vents    
                                       1
                                      0.9
                                      0.9
                                  0[[][2][]]
                                       0
                                       0
                                       0
                                       0
                                       0
                                     0.0 
  Notification of storage vessel inspection
                                       1
                                      0.9
                                      0.9
                                  0[[][2][]]
                                       0
                                       0
                                       0
                                       0
                                       0
                                     0.0 
  Notification of reconstruction-process vent control device 
                                       4
                                      0.4
                                      1.6
                                  0[[][2][]]
                                       0
                                       0
                                       0
                                       0
                                       0
                                     0.0 
  Notification of performance test  
                                    See 4B
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
  Startup, shutdown and malfunction reports
                                      NA
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Semiannual compliance reports:  reports:
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Table B.2 Model Refinery  -  40 CFR Part 63, Subpart CC Supporting Statement Analysis (Cont.) [1]
                                  Burden item
                                      (A)
                                      (B)
                                      (C)
                                      (D)
                                      (E)
                                      (F)
                                      (G)
                                      (H)
                                      (I)
                                      (J)
                                       
        Person-hours per occurrence for SFI (from supporting statement)
    No. of occurrences per respondent per year (from supporting statement)
       Person-hours per respondent per year (from supporting statement)
           Person-hours per occurrence applicable to Model Refinery
              No. of occurrences for the Model Refinery per year
                 Person-hours for the Model Refinery per year
                            Technical Hours
(hr/yr)
                           Managerial Hours
(hr/yr)
                            Clerical Hours
(hr/yr)
  Total Cost ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr
                                       
                                       
                                       
                                    (C=AxB)
                                       
                                       
                                       
                                     (G=F)
                                  (H=G*0.05)
                                  (I=G*0.10)
                                       
   i.  General 
                                      18
                                       2
                                      36
                                      18
                                       2
                                      36
                                      36
                                      1.8
                                      3.6
                                   3,337.7 
   ii. Storage vessels  
                                       1
                                      18
                                      18
                                  1[[][7][]]
                                  8[[][8][]]
                                       8
                                       8
                                      0.4
                                      0.8
                                    741.7 
   iii. Storage vessels  seal gap failure       
                                       3
                                       2
                                       6
                                  3[[][7][]]
                                 0.9[[8,9][]]
                                       3
                                       3
                                     0.15
                                      0.3
                                    278.1 
   iv. Process units  - LDAR 
                                       3
                                      22
                                      66
                                       3
                                      32
                                      96
                                      96
                                      4.8
                                      9.6
                                   8,900.5 
   v. Process vents    
                                      1.5
                                       4
                                       6
                                      1.5
                                   6[[10][]]
                                       9
                                       9
                                     0.45
                                      0.9
                                    834.4 
5.  Recordkeeping Requirements
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
A.  Read instructions
                                    See 4A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
B.  Plan activities
                                    See 4A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
C.  Implement activities
                                    See 4B
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
D.  Develop record system  
                                      N A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
   Initial:
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
    i. Storage vessels  
                                       2
                                      0.9
                                      1.8
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
    ii. Process units  - LDAR
                                      75
                                      1.1
                                     82.5
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
    iii. Process vents    
                                       2
                                      0.9
                                      1.8
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
  Periodic
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
    i. Storage vessels  
                                       2
                                      18
                                      36
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
                                     0.0 
    ii. Process units  - LDAR 
                                       
                                       
                                       
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
                                     0.0 
    iii. Process vents    
                                       2
                                       9
                                      18
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
                                     0.0 
E.  Time to enter information and transmit it
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
  Initial:
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
    i. Storage vessels  
                                       6
                                      0.9
                                      3.6
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
    ii. Process units  - LDAR 
                                      99
                                      1.1
                                      108
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Table B.2 Model Refinery  -  40 CFR Part 63, Subpart CC Supporting Statement Analysis (Cont.) [1]
                                  Burden item
                                      (A)
                                      (B)
                                      (C)
                                      (D)
                                      (E)
                                      (F)
                                      (G)
                                      (H)
                                      (I)
                                      (J)
                                       
        Person-hours per occurrence for SFI (from supporting statement)
    No. of occurrences per respondent per year (from supporting statement)
       Person-hours per respondent per year (from supporting statement)
           Person-hours per occurrence applicable to Model Refinery
              No. of occurrences for the Model Refinery per year
                 Person-hours for the Model Refinery per year
                            Technical Hours
(hr/yr)
                           Managerial Hours
(hr/yr)
                            Clerical Hours
(hr/yr)
  Total Cost ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr
                                       
                                       
                                       
                                    (C=AxB)
                                       
                                       
                                       
                                     (G=F)
                                  (H=G*0.05)
                                  (I=G*0.10)
                                       
    iii. Process vents    
                                      12
                                      0.2
                                      24
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
  Periodic
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
    i. Storage vessels  
                                      3.5
                                      18
                                      63
                                    0[[4]]
                                      16
                                       0
                                       0
                                       0
                                       0
                                     0.0 
    ii. Process units  - LDAR
                                      99
                                      11
                                     1,089
                                 1[[5,1][1][]]
                                      16
                                      16
                                      16
                                      0.8
                                      1.6
                                   1,483.4 
    iii. Process vents    
                                      15
                                       4
                                      60
                                      15
                                   6[[10][]]
                                      90
                                      90
                                      4.5
                                       9
                                   8,344.3 
F.  Time to train personnel
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
   Initial: 
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
     i. Storage vessels  
                                       1
                                      0.9
                                      0.9
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
     ii. Process units  - LDAR 
                                       
                                       
                                       
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
     iii. Process vents    
                                       1
                                      0.4
                                      0.4
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
  Periodic
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
     i. Storage vessels  
                                      NA
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
     ii. Process units  - LDAR 
                                       
                                       
                                       
                                   0.5[[5]]
                                      16
                                       8
                                       8
                                      0.4
                                      0.8
                                    741.7 
     iii. Process vents
                                       1
                                       4
                                       4
                                       1
                                       3
                                       3
                                       3
                                     0.15
                                      0.3
                                    278.1 
TOTAL with Paper Reporting Paper (Sum of Items 1 through 4)
                                    18,357
TOTAL with Electronic Reporting (Sum of Periodic Items under 4.A and 4.B)
                                     4,265
TOTAL Record Keeping (Sum of Periodic Items under 5.D, 5.E, and 5.F)
                                    10,848
[1] The referenced supporting statement contains several footnotes associated with the original burden estimate. Please refer to the original supporting statement, included in the rulemaking docket. 
[2] For the purposes of the Model Plant burden estimate, we are excluding the cost of reporting associated with construction and reconstruction of existing plants. The SFI estimated that 10% of existing facilities would be affected by this reporting burden.
[3] For the purposes of the Model Plant burden estimate, we are excluding the cost of repeating performance tests. 
[4] Required activities reporting burden is accounted for in the HON - Subpart G and has been set equal to zero in the Subpart CC analysis. 
[5] The LDAR burden is reflected here, in the Subpart CC burden. The Subpart VV burden estimate has been set equal to zero for LDAR to avoid double counting. 
[6] Assumed three process vents - the number of Subpart CC applicable miscellaneous process vents - note that the isomerization unit and the No. 3 Ultraformer share a common process vent control device. 
Table B.2 Model Refinery  -  40 CFR Part 63, Subpart CC Supporting Statement Analysis (Cont.) [1]

[7] The HON storage burden estimate for the model refinery was done using a table modeled from the subpart Kb Burden table (B-6).  Because Subpart Kb does not require semiannual reporting, the semiannual reporting requirements have been maintained in the Subpart CC analysis.
[8] Number of occurrences have been reduced by half since the HON accounts for half of the burden through annual reporting. The HON ICR analysis used annual reporting instead of semiannual because it directly copied the methodology in the 40 CFR Part 60, Subpart Kb ICR, which only requires reports of the gap measurement results once per year.
[9] Assumed the same non-compliance rate (1/9) as the original Subpart CC SFI. 
[10] Semiannual reports for three control devices. 
[11] Typo in the Subpart CC ICR Table. Footnote in original table clarifies the correct number is 77; changed to 1 hour because Method 21 testing is counted in cost impacts and 1 hour per process unit should be adequate time to transmit the data from the analyzer to a computer.


Table B.3 Model Refinery  -  40 CFR Part 60, Subpart K Supporting Statement Analysis [[1]]

                                  Burden item
                                      (A)
                                      (B)
                                      (C)
                                      (D)
                                      (E)
                                      (F)
                                      (G)
                                      (H)
                                      (I)
                                      (J)
                                       
        Person-hours per occurrence for SFI (from supporting statement)
    No. of occurrences per respondent per year (from supporting statement)
       Person-hours per respondent per year (from supporting statement)
           Person-hours per occurrence applicable to Model Refinery
              No. of occurrences for the Model Refinery per year
                 Person-hours for the Model Refinery per year
                            Technical Hours
(hr/yr)
                           Managerial Hours
(hr/yr)
                            Clerical Hours
(hr/yr)
  Total Cost ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr
                                       
                                       
                                       
                                    (C=AxB)
                                       
                                       
                                       
                                     (G=F)
                                  (H=G*0.05)
                                  (I=G*0.10)
                                       
1.  Applications
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
2.  Survey and Studies
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
3.  Acquisition, Installation, and Utilization of Technology and Systems
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
4.  Reporting Requirements
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
  A.  Read instructions
                                Included in 4E
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
  B.  Required activities:
                                Included in 4E
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
    iii.  Monitoring of operations and emissions
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
D.  Gather Existing Information
                                Included in 4E
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
E.  Write report
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
    i.  Notification of reconstruction/modification   
                                       4
                                       1
                                       4
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
5.  Recordkeeping Requirements
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
 A.  Read instructions
                                Included in 4E
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
 B.  Plan activities
                                Included in 4E
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
C.  Implement activities
                                Included in 4E
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
D.  Develop record system
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
E.  Time to enter and transmit    information:  
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
  i.  Records of startup, shutdown, or malfunction  
                                       1
                                       1
                                       1
                                       1
                                       3
                                       3
                                       3
                                     0.15
                                      0.3
                                    278.14
Table B.3 Model Refinery  -  40 CFR Part 60, Subpart K Supporting Statement Analysis (Cont.) [1]

                                  Burden item
                                      (A)
                                      (B)
                                      (C)
                                      (D)
                                      (E)
                                      (F)
                                      (G)
                                      (H)
                                      (I)
                                      (J)
                                       
        Person-hours per occurrence for SFI (from supporting statement)
    No. of occurrences per respondent per year (from supporting statement)
       Person-hours per respondent per year (from supporting statement)
           Person-hours per occurrence applicable to Model Refinery
              No. of occurrences for the Model Refinery per year
                 Person-hours for the Model Refinery per year
                            Technical Hours
(hr/yr)
                           Managerial Hours
(hr/yr)
                            Clerical Hours
(hr/yr)
  Total Cost ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr
                                       
                                       
                                       
                                    (C=AxB)
                                       
                                       
                                       
                                     (G=F)
                                  (H=G*0.05)
                                  (I=G*0.10)
                                       
  ii.  Record petroleum liquid           stored
                                      0.5
                                       1
                                      0.5
                                      0.5
                                       3
                                      1.5
                                      1.5
                                     0.075
                                     0.15
                                    139.07
  iii.  Record of storage                    performance tests
                                      0.5
                                       1
                                      0.5
                                      0.5
                                       3
                                      1.5
                                      1.5
                                     0.075
                                     0.15
                                    139.07
  iv.  Record true vapor pressure of liquid stored
                                       1
                                       1
                                       1
                                       1
                                       3
                                       3
                                       3
                                     0.15
                                      0.3
                                    278.14
F.  Time to train personnel
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
G. Time for audits
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
TOTAL with Paper Reporting Paper
                                       0
TOTAL with Electronic Reporting
                                       0
TOTAL Record Keeping (Sum of Items under 5.E)
                                      834
[1] The referenced supporting statement contains several footnotes associated with the original burden estimate. Please refer to the original supporting statement, included in the rulemaking docket. 


Table B.4 Model Refinery  -  40 CFR Part 60, Subpart Ka Supporting Statement Analysis [1]

                                  Burden item
                                      (A)
                                      (B)
                                      (C)
                                      (D)
                                      (E)
                                      (F)
                                      (G)
                                      (H)
                                      (I)
                                       
        Person-hours per occurrence for SFI (from supporting statement)
    No. of occurrences per respondent per year (from supporting statement)
           Person-hours per occurrence applicable to Model Refinery
              No. of occurrences for the Model Refinery per year
                 Person-hours for the Model Refinery per year
                            Technical Hours
(hr/yr)
                           Managerial Hours
(hr/yr)
                            Clerical Hours
(hr/yr)
  Total Cost ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr
                                       
                                       
                                       
                                       
                                       
                                       
                                     (F=E)
                                  (G=F*0.05)
                                  (H=F*0.10)
                                       
1. Applications
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
2. Surveys and Studies
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
3. Reporting Requirements
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
A. Read Instruction
                                Included in 3B.
                                       
                                       
                                       
                                       
                                       
                                       
                                       
B. Required Activities
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Vapor recovery information
                                      20
                                       1
                                      20
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
Measure seal gap
                                Included in 4E.
                                       
                                       
                                       
                                       
                                       
                                       
                                       
C. Create Information
                                Included in 3B.
                                       
                                       
                                       
                                       
                                       
                                       
                                       
D. Gather Existing  Information
                                       1
                                       1
                                       1
                                       1
                                       1
                                       1
                                     0.05
                                      0.1
                                     92.71
E. Write Report
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Notification of construction
                                       2
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Notification of actual startup
                                       2
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
  Notification of gap measurement
                                      1.5
                                       1
                                      1.5
                                    4[[3]]
                                       6
                                       6
                                      0.3
                                      0.6
                                    556.28
Report of seal gap excess
                                      2.5
                                     0.03
                                      2.5
                                   0.4[[4]]
                                       1
                                       1
                                     0.05
                                      0.1
                                     92.71
Information on vapor recovery
                                Included in 3B.
                                       
                                       
                                       
                                       
                                       
                                       
                                       
4. Recordkeeping Requirements
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
A. Read Instructions
                                Included in 3B.
                                       
                                       
                                       
                                       
                                       
                                       
                                       
B. Plan Activities
                                Included in 3B
                                       
                                       
                                       
                                       
                                       
                                       
                                       
C. Implement Activities
                                Included in 3B
                                       
                                       
                                       
                                       
                                       
                                       
                                       
D. Develop Record
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
E. Time to Enter
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
New tank seal gap measurements
                                      250
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Secondary seal gap
                                   250[[5]]
                                       1
                                       5
                                       4
                                      20
                                      20
                                       1
                                       2
                                   1,854.28

Table B.4 Model Refinery  -  40 CFR Part 60, Subpart Ka Supporting Statement Analysis (Cont.) [1]

                                  Burden item
                                      (A)
                                      (B)
                                      (C)
                                      (D)
                                      (E)
                                      (F)
                                      (G)
                                      (H)
                                      (I)
                                       
        Person-hours per occurrence for SFI (from supporting statement)
    No. of occurrences per respondent per year (from supporting statement)
           Person-hours per occurrence applicable to Model Refinery
              No. of occurrences for the Model Refinery per year
                 Person-hours for the Model Refinery per year
                            Technical Hours
(hr/yr)
                           Managerial Hours
(hr/yr)
                            Clerical Hours
(hr/yr)
  Total Cost ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr
                                       
                                       
                                       
                                       
                                       
                                       
                                     (F=E)
                                  (G=F*0.05)
                                  (H=F*0.10)
                                       
Primary seal gap measurements
                                    20[[5]]
                                      0.2
                                       2
                                   0.8[[3]]
                                      1.6
                                      1.6
                                     0.08
                                     0.16
                                    148.34
Fill/refill record
                                  2[[][6][]]
                                       1
                                      0.2
                                       3
                                      0.6
                                      0.6
                                     0.03
                                     0.06
                                     55.63
TOTAL with Paper Reporting Paper (Sum  3.B, 3.C, 3.D, 3.E)
                                      742
TOTAL with Electronic Reporting (Item 3.D)
                                      93
TOTAL Record Keeping (Sum of Items under 4.E)
                                     2,058
[1] The referenced supporting statement contains several footnotes associated with the original burden estimate. Please refer to the original supporting statement, included in the rulemaking docket. 
[2] Vapor recovery is not used on any storage tanks in the model refinery.
[3] The seal gap measurements apply only to the 4 external floating roofs (EFRs); therefore, 4 occurrences per year for the annual requirement and 0.8 for the 5 year requirement. 
[4] Assumed the same non-compliance rate (1/9) as in the Subpart CC supporting statement.
[5] The 250 hours in the SFI is 5 hours per tank and 50 tanks per facility.  The 20 hours in the SFT represents 2 hours per tank for 20% of the tanks at the facility (50 tanks) for a total of 20 hours.  The 5 and 2 hour/tank burden estimates were used for the model refinery estimate.
[6] The SFI used an estimate of 0.2 hours per tank for the fill or refill record, or a total of 2 hours for 20% of the tanks.  The model refinery has a total of 15 tanks subject to subpart Ka or 3 tanks requiring fill/refill records.


Table B.5 Model Refinery  -  40 CFR Part 60, Subpart Kb Supporting Statement Analysis [1]
                                  Burden item
                                      (A)
                                      (B)
                                      (C)
                                      (D)
                                      (E)
                                      (F)
                                      (G)
                                      (H)
                                      (I)
                                       
        Person-hours per occurrence for SFI (from supporting statement)
    No. of occurrences per respondent per year (from supporting statement)
           Person-hours per occurrence applicable to Model Refinery
              No. of occurrences for the Model Refinery per year
                 Person-hours for the Model Refinery per year
                            Technical Hours
(hr/yr)
                           Managerial Hours
(hr/yr)
                            Clerical Hours
(hr/yr)
  Total Cost ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr
                                       
                                       
                                       
                                       
                                       
                                       
                                     (F=E)
                                  (G=F*0.05)
                                  (H=F*0.10)
                                       
1. Applications
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
2. Surveys and Studies
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
3. Reporting Requirements
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
A. Read Instruction
                                       1
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
B. Required Activities 
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
One-Time Only Requirements
                                       2
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Notification of Start of Construction
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Notification of Actual Startup
                                       2
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Notification of Physical or Operational Changes
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Notification of Malfunction
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Notification of Initial                     Inspection
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
IFR Internal Inspection
                                       2
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
EFR Gap Measurement
                                       2
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
    Initial Inspection Report
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
IFR Internal Inspection Report
                                      12
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
EFR 2nd Seal Gap Measurement
                                       8
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
EFR 1st Seal Gap Measurement
                                      12
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
CVS Operating Plan Report 
                                       8
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0


Table B.5 Model Refinery  -  40 CFR Part 60, Subpart Kb Supporting Statement Analysis (Cont.) [1]
                                  Burden item
                                      (A)
                                      (B)
                                      (C)
                                      (D)
                                      (E)
                                      (F)
                                      (G)
                                      (H)
                                      (I)
                                       
        Person-hours per occurrence for SFI (from supporting statement)
    No. of occurrences per respondent per year (from supporting statement)
           Person-hours per occurrence applicable to Model Refinery
              No. of occurrences for the Model Refinery per year
                 Person-hours for the Model Refinery per year
                            Technical Hours
(hr/yr)
                           Managerial Hours
(hr/yr)
                            Clerical Hours
(hr/yr)
  Total Cost ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr
                                       
                                       
                                       
                                       
                                       
                                       
                                     (F=E)
                                  (G=F*0.05)
                                  (H=F*0.10)
                                       
Repeat Requirements
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Internal IFR Inspection
                                      12
                                       1
                                      12
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Visual IFR Inspection
                                       8
                                       1
                                       8
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Report of IFR Failure
                                       2
                                       1
                                       2
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
    Notification of Delay of Repair or Emptying for IFR
                                       4
                                       1
                                       4
                                  0[[][2][]]
                                       0
                                       0
                                       0
                                       0
                                       0
EFR 2nd Seal Gap Measure Report
                                       8
                                       1
                                       8
                                  22[[][3][]]
                                      176
                                      176
                                      8.8
                                     17.6
                                   16,317.66
EFR 1st Seal Gap Measure Report
                                      12
                                       1
                                      12
                                 4.4[[][4][]]
                                     52.8
                                     52.8
                                     2.64
                                     5.28
                                   4,895.30
Notification of Refill
                                       2
                                       1
                                       2
                                 4.4[[][4][]]
                                      8.8
                                      8.8
                                     0.44
                                     0.88
                                    815.88
       Number of Responses 
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
 4.RECORDKEEPING REQUIREMENTS
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
 A.. Read Instructions
                                       1
                                       1
                                       1
                                       1
                                       1
                                       1
                                     0.05
                                      0.1
                                     92.71
 B. Gather and Record Information 
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
   i.  Vessel Volumes, Liquid Vapor Pressure, flares
                                       8
                                       1
                                       8
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
    ii.  113b(a) inspection 
                                      12
                                       1
                                      12
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
   iii. 113b(b) gap measurement for Secondary Seal
                                      12
                                       1
                                       5
                                  22[[][2][]]
                                      110
                                      110
                                      5.5
                                      11
                                   10,198.54
   iii. 113b(b) gap measurement for Primary Seal
                                       
                                       
                                       5
                                 4.4[[][4][]]
                                      22
                                      22
                                      1.1
                                      2.2
                                   2,039.71
C. Develop Record System 
                                      10
                                       1
                                       0
                                       0
                                       0
                                       
                                       
                                       
                                       
D. Time to Enter Information - CVS Parameter Records
                                       2
                                      52
                                       2
                                  0[[][5][]]
                                       0
                                       0
                                       0
                                       0
                                       0
Table B.5 Model Refinery  -  40 CFR Part 60, Subpart Kb Supporting Statement Analysis (Cont.) [1]
                                  Burden item
                                      (A)
                                      (B)
                                      (C)
                                      (D)
                                      (E)
                                      (F)
                                      (G)
                                      (H)
                                      (I)
                                       
        Person-hours per occurrence for SFI (from supporting statement)
    No. of occurrences per respondent per year (from supporting statement)
           Person-hours per occurrence applicable to Model Refinery
              No. of occurrences for the Model Refinery per year
                 Person-hours for the Model Refinery per year
                            Technical Hours
(hr/yr)
                           Managerial Hours
(hr/yr)
                            Clerical Hours
(hr/yr)
  Total Cost ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr
                                       
                                       
                                       
                                       
                                       
                                       
                                     (F=E)
                                  (G=F*0.05)
                                  (H=F*0.10)
                                       
F. Train Personnel
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
G. Audits
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
TOTAL with Paper Reporting Paper (Sum of Items 1 through 3)
                                    22,029
TOTAL with Electronic Reporting
                                       0
TOTAL Record Keeping (Sum of Items under 4.A and 4.B)
                                    12,331
[1] The referenced supporting statement contains several footnotes associated with the original burden estimate. Please refer to the original supporting statement, included in the rulemaking docket. 
[2] The model refinery does not have any IFR tanks subject to subpart Kb.
[3] 22 external floating roof (EFR) tanks subject to Part 60, Subpart Kb. The SFI assumed 12 hours for an average of 2.5 EFR tanks, or about 5 hours per EFR.
[4] This measurement occurs only once every 5 years, so the number should be 1/5 of the number of occurrences for the secondary seal measurements. 
[5] Requirement is for closed vent system and control device. Model refinery does not use closed vent system and control to comply with subpart Kb.



Table B.6 Model Refinery  -  40 CFR Part 60, Subpart G Supporting Statement Analysis [[1][,2][]]
                                  Burden item
                                      (A)
                                      (B)
                                      (C)
                                      (D)
                                      (E)
                                      (F)
                                      (G)
                                      (H)
                                      (I)
                                       
        Person-hours per occurrence for SFI (from supporting statement)
    No. of occurrences per respondent per year (from supporting statement)
           Person-hours per occurrence applicable to Model Refinery
              No. of occurrences for the Model Refinery per year
                 Person-hours for the Model Refinery per year
                            Technical Hours
(hr/yr)
                           Managerial Hours
(hr/yr)
                            Clerical Hours
(hr/yr)
  Total Cost ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr
                                       
                                       
                                       
                                       
                                       
                                       
                                     (F=E)
                                  (G=F*0.05)
                                  (H=F*0.10)
                                       
1. Applications
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
2. Surveys and Studies
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
3. Reporting Requirements
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
A. Read Instruction
                                       1
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
B. Required Activities 
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
One-Time Only Requirements
                                       2
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Notification of Start of Construction
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Notification of Actual Startup
                                       2
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Notification of Physical or Operational Changes
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Notification of Malfunction
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Notification of Initial Inspection
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
IFR Internal Inspection
                                       2
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
EFR Gap Measurement
                                       2
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
    Initial Inspection Report
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
IFR Internal Inspection Report
                                      12
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
EFR 2nd Seal Gap Measurement
                                       8
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
EFR 1st Seal Gap Measurement
                                      12
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
CVS Operating Plan Report 
                                       8
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Repeat Requirements
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
    Internal IFR Inspection
                                      12
                                       1
                                      12
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
    Visual IFR Inspection
                                       8
                                       1
                                       8
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
    Report of IFR Failure
                                       2
                                       1
                                       2
                                    0[[3]]
                                       0
                                       0
                                       0
                                       0
                                       0

Table B.6 Model Refinery  -  40 CFR Part 60, Subpart G Supporting Statement Analysis (Cont.) [[1][,2][]]
                                  Burden item
                                      (A)
                                      (B)
                                      (C)
                                      (D)
                                      (E)
                                      (F)
                                      (G)
                                      (H)
                                      (I)
                                       
        Person-hours per occurrence for SFI (from supporting statement)
    No. of occurrences per respondent per year (from supporting statement)
           Person-hours per occurrence applicable to Model Refinery
              No. of occurrences for the Model Refinery per year
                 Person-hours for the Model Refinery per year
                            Technical Hours
(hr/yr)
                           Managerial Hours
(hr/yr)
                            Clerical Hours
(hr/yr)
  Total Cost ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr
                                       
                                       
                                       
                                       
                                       
                                       
                                     (F=E)
                                  (G=F*0.05)
                                  (H=F*0.10)
                                       
    Notification of Delay of Repair or Emptying for IFR
                                       4
                                       1
                                       4
                                  0[[][3][]]
                                       0
                                       0
                                       0
                                       0
                                       0
EFR 2nd Seal Gap Measure Report
                                       8
                                       1
                                       8
                                  8[[][4][]]
                                      64
                                      64
                                      3.2
                                      6.4
                                   5,933.70
EFR 1st Seal Gap Measure Report
                                      12
                                       1
                                      12
                                 1.6[[][4][]]
                                     19.2
                                     19.2
                                     0.96
                                     1.92
                                   1,780.11
Notification of Refill
                                       2
                                       1
                                       2
                                 1.6[[][4][]]
                                      3.2
                                      3.2
                                     0.16
                                     0.32
                                    296.68
       Number of Responses 
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
 4.RECORDKEEPING REQUIREMENTS
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
 A.. Read Instructions
                                       1
                                       1
                                       1
                                       1
                                       1
                                       1
                                     0.05
                                      0.1
                                     92.71
 B. Gather and Record Information 
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
i.  Vessel Volumes, Liquid Vapor Pressure, flares
                                       8
                                       1
                                       8
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
 ii.  113b(a) inspection 
                                      12
                                       1
                                      12
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
iii. 113b(b) gap measurement for Secondary Seal
                                      12
                                       1
                                       5
                                  8[[][4][]]
                                      40
                                      40
                                       2
                                       4
                                   3,708.56
iii. 113b(b) gap measurement for Primary Seal
                                       
                                       
                                       5
                                 1.6[[][4][]]
                                       8
                                       8
                                      0.4
                                      0.8
                                    741.71
C. Develop Record System 
                                      10
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
D. Time to Enter Information - CVS Parameter Records
                                       2
                                      52
                                       2
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
F. Train Personnel
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
G. Audits
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
TOTAL with Paper Reporting Paper (Sum of Items 1 through 3)
                                     8,010
TOTAL with Electronic Reporting
                                       0
TOTAL Record Keeping (Sum of Items under 4.A and 4.B)
                                     4,543
[1] Original Subpart G supporting statement was unavailable for the analysis; therefore, Subpart Kb was used to estimate the burden under Subpart G.
[2] The referenced supporting statement contains several footnotes associated with the original burden estimate. Please refer to the original supporting statement, included in the rulemaking docket. 
[3] The model refinery has no IFR tanks subject to subpart G or CC.
[4] 8 EFR's are subject to Subpart CC/Subpart G - one gap measurement per year equates to 8 occurrences; one measurement every 5 years equates to 1.6 occurrences.
Table B.7 Model Refinery  -  40 CFR Part 60, Subpart VV Supporting Statement Analysis [[1][,2][]]
                                 Burden item 
                                      (A)
                                      (B)
                                      (C)
                                      (D)
                                      (E)
                                      (F)
                                      (G)
                                      (H)
                                      (I)

        Person-hours per occurrence for SFI (from supporting statement)
    No. of occurrences per respondent per year (from supporting statement)
           Person-hours per occurrence applicable to Model Refinery 
              No. of occurrences for the Model Refinery per year
                 Person-hours for the Model Refinery per year
                            Technical Hours
(hr/yr)
                           Managerial Hours
(hr/yr)
                            Clerical Hours
(hr/yr)
  Total Cost ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr

 
 
 
 
                                       
                                     (F=E)
                                  (G=F*0.05)
                                  (H=F*0.10)
                                       
1. Applications
                                      N/A
 
                                       
                                       
                                       
                                       
                                       
                                       
                                       
2. Survey and Studies
                                      N/A
 
                                       
                                       
                                       
                                       
                                       
                                       
                                       
3. Reporting Requirements
 
 
                                       
                                       
                                       
                                       
                                       
                                       
                                       
A. Read Instructions
                                       1
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                      0 
B. Required Activities
                                      48
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                      0 
Initial Performance Test Report
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Repeat Performance Test Report
                                      48
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                      0 
C. Create Information
                                Included in 3B
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
D. Gather Existing Information
                                Included in 3E
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
E. Write Report
                                       2
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                      0 
New Sources
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Notification of Construction 
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
     Notification of Reconstruction/ Modification
                                       2
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                      0 
     Notification of Actual Startup
                                       2
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                      0 
     Notification of Initial/Repeat Performance Test
                                       2
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                      0 
     Existing Sources Semiannual Report
                                       4
                                       2
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                      0 
4. Recordkeeping Requirements
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
A. Read Instructions
                                Included in 3A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
B. Plan Activities
                                Included in 4C
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
C. Implement Activities
                                Included in 3B
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
D. Develop Record System
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
E. Time to Enter Information
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Records of Operating Parameters
                                      80
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                      0 
Table B.7 Model Refinery  -  40 CFR Part 60, Subpart VV Supporting Statement Analysis (Cont.) [[1][,2][]]
                                 Burden item 
                                      (A)
                                      (B)
                                      (C)
                                      (D)
                                      (E)
                                      (F)
                                      (G)
                                      (H)
                                      (I)

        Person-hours per occurrence for SFI (from supporting statement)
    No. of occurrences per respondent per year (from supporting statement)
           Person-hours per occurrence applicable to Model Refinery 
              No. of occurrences for the Model Refinery per year
                 Person-hours for the Model Refinery per year
                            Technical Hours
(hr/yr)
                           Managerial Hours
(hr/yr)
                            Clerical Hours
(hr/yr)
  Total Cost ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr

 
 
 
 
                                       
                                     (F=E)
                                  (G=F*0.05)
                                  (H=F*0.10)
                                       
F. Train personnel
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
G. Audits
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
TOTAL with Paper Reporting Paper
                                      0 
TOTAL with Electronic Reporting
                                      0 
TOTAL Record Keeping
                                      0 
[1] The referenced supporting statement contains several footnotes associated with the original burden estimate. Please refer to the original supporting statement, included in the rulemaking docket. 
[2] All record keeping and reporting burden for Subpart VV is accounted for under Subpart CC.

Table B.8 Model Refinery  -  40 CFR Part 61, Subpart V Supporting Statement Analysis [[1][,2][]]
                                 Burden item 
                                      (A)
                                      (B)
                                      (C)
                                      (D)
                                      (E)
                                      (F)
                                      (G)
                                      (H)
                                      (I)

        Person-hours per occurrence for SFI (from supporting statement)
    No. of occurrences per respondent per year (from supporting statement)
           Person-hours per occurrence applicable to Model Refinery 
              No. of occurrences for the Model Refinery per year
                 Person-hours for the Model Refinery per year
                            Technical Hours
(hr/yr)
                           Managerial Hours
(hr/yr)
                            Clerical Hours
(hr/yr)
  Total Cost ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr

 
 
 
 
                                       
                                     (F=E)
                                  (G=F*0.05)
                                  (H=F*0.10)
                                       
1. Applications
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
2. Survey and Studies
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
3. Reporting Requirements
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
A. Read Instructions
                                       1
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
B. Required Activities
                                      20
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Initial Performance Test
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Reference Method 21/22 Tests
                                       4
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Repeat Performance Test
                                      20
                                      0.2
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
C. Create Information
                                    See 3B
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
D. Gather Existing Information
                                    See 3B
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
E. Write Report
                                       2
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Notification of Construction/
Reconstruction
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Notification of Anticipated Startup
                                       2
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Notification of Actual Startup
                                       2
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Notification of Initial Performance Test
                                       2
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Report of Performance Test
                                    See 3B
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Application for Alternative
                                      10
                                       1
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Initial Report
                                       8
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
  Semiannual Report
                                      30
                                       2
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
4. Recordkeeping Requirements
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
A. Read Instructions
                                    See 3A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
B. Plan Activities
                                    See 4C
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
C. Implement Activities
                                    See 3B
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Table B.8 Model Refinery  -  40 CFR Part 61, Subpart V Supporting Statement Analysis (Cont.) [[1][,2][]]
                                 Burden item 
                                      (A)
                                      (B)
                                      (C)
                                      (D)
                                      (E)
                                      (F)
                                      (G)
                                      (H)
                                      (I)

        Person-hours per occurrence for SFI (from supporting statement)
    No. of occurrences per respondent per year (from supporting statement)
           Person-hours per occurrence applicable to Model Refinery 
              No. of occurrences for the Model Refinery per year
                 Person-hours for the Model Refinery per year
                            Technical Hours
(hr/yr)
                           Managerial Hours
(hr/yr)
                            Clerical Hours
(hr/yr)
  Total Cost ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr

 
 
 
 
                                       
                                     (F=E)
                                  (G=F*0.05)
                                  (H=F*0.10)
                                       
D. Develop Record System
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
E. Time to Enter Information
                                      1.5
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Records of startups, shutdown, malfunction, etc.
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Records of operating, parameters and emissions
                                      0.1
                                      365
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Records of leak detected
                                      0.4
                                      52
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
F. Train personnel
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
G. Audits
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
TOTAL with Paper Reporting Paper
                                       0
TOTAL with Electronic Reporting
                                       0
TOTAL Record Keeping
                                       0
[1] The referenced supporting statement contains several footnotes associated with the original burden estimate. Please refer to the original supporting statement, included in the rulemaking docket. 
[2] Pursuant to Subpart CC, since the model refinery is subject to CC and an Equipment Leak rule in Part 60 or Part 61, the facility only complies with Subpart CC. All model process units subject to Subpart V are also subject to Subpart CC; therefore, the values for the Subpart V analysis are zero.


Table B.9 Model Refinery  -  40 CFR Part 61, Subpart GGG Supporting Statement Analysis [[1][,2][]]
                                 Burden item 
                                      (A)
                                      (B)
                                      (C)
                                      (D)
                                      (E)
                                      (F)
                                      (G)
                                      (H)
                                      (I)
                                      (J)

        Person-hours per occurrence for SFI (from supporting statement)
    No. of occurrences per respondent per year (from supporting statement)
       Person-hours per respondent per year (from supporting statement)
           Person-hours per occurrence applicable to Model Refinery 
              No. of occurrences for the Model Refinery per year
                 Person-hours for the Model Refinery per year
                            Technical Hours
(hr/yr)
                           Managerial Hours
(hr/yr)
                            Clerical Hours
(hr/yr)
  Total Cost ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr

 
 
                                    (C=AxB)
 
 
                                       
                                     (G=F)
                                  (H=G*0.05)
                                  (I=G*0.10)
                                       
1. APPLICATIONS (Not Applicable)
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
2. SURVEY AND STUDIES (Not Applicable)
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
3. REPORT REQUIREMENTS
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
A. Read Instructions
                                       1
                                       1
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
B. Required Activities
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Initial performance test
                                      24
                                       1
                                      24
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Repeat performance test
                                      24
                                       1
                                      24
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
C. Create Information (Included in 3B)
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
D. Gather Existing Information (Included in 3E)
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
E. Write Report
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Notification of construction or reconstruction
                                       2
                                       1
                                       2
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Notification of anticipated startup
                                       2
                                       1
                                       2
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Notification of actual startup
                                       2
                                       1
                                       2
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Notification of initial performance test
                                       2
                                       1
                                       2
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Report of performance test (Included in 3B)
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Semiannual work practice reports
                                       8
                                       2
                                      16
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Subtotal for Reports
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
4. RECORDKEEPING REQUIREMENTS
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Table B.9 Model Refinery  -  40 CFR Part 61, Subpart GGG Supporting Statement Analysis (Cont.) [[1][,2][]]
                                 Burden item 
                                      (A)
                                      (B)
                                      (C)
                                      (D)
                                      (E)
                                      (F)
                                      (G)
                                      (H)
                                      (I)
                                      (J)

        Person-hours per occurrence for SFI (from supporting statement)
    No. of occurrences per respondent per year (from supporting statement)
       Person-hours per respondent per year (from supporting statement)
           Person-hours per occurrence applicable to Model Refinery 
              No. of occurrences for the Model Refinery per year
                 Person-hours for the Model Refinery per year
                            Technical Hours
(hr/yr)
                           Managerial Hours
(hr/yr)
                            Clerical Hours
(hr/yr)
  Total Cost ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr

 
 
                                    (C=AxB)
 
 
                                       
                                     (G=F)
                                  (H=G*0.05)
                                  (I=G*0.10)
                                       
A. Read Instructions (Included in 3A)
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
B. Plan Activities (Included in 3B)
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
C. Implement Activities (Included in 3B)
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
D. Develop Record System (Not Applicable)
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
E. Time to Enter Information
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Records of operating parameters
                                      0.3
                                      365
                                     109.5
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
F. Train Personnel (Not Applicable)
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
G. Audits (Not Applicable)
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Subtotal for Recordkeeping
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
5. Total Annual Labor Hours and Cost (rounded)
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
TOTAL with Paper Reporting Paper
                                       0
TOTAL with Electronic Reporting
                                       0
TOTAL Record Keeping
                                       0
[1] The referenced supporting statement contains several footnotes associated with the original burden estimate. Please refer to the original supporting statement, included in the rulemaking docket. 

[2] Burden analysis for Subpart GGG is zero since units at the model refinery are also subject to Subpart VV and are complying with Subpart GGG by complying with Subpart VV. Burden is accounted for in Subpart VV. 

                                       

Table B.10 Model Refinery  -  40 CFR Part 61, Subpart GGGa Supporting Statement Analysis [[1][,2][]]
                                  Burden item
                                      (A)
                                      (B)
                                      (C)
                                      (D)
                                      (E)
                                      (F)
                                      (G)
                                      (H)
                                      (I)
                                      (J)
                                       
        Person-hours per occurrence for SFI (from supporting statement)
    No. of occurrences per respondent per year (from supporting statement)
       Person-hours per respondent per year (from supporting statement)
           Person-hours per occurrence applicable to Model Refinery
              No. of occurrences for the Model Refinery per year
                 Person-hours for the Model Refinery per year
                            Technical Hours
(hr/yr)
                           Managerial Hours
(hr/yr)
                            Clerical Hours
(hr/yr)
  Total Cost ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr
                                       
                                       
                                       
                                    (C=AxB)
                                       
                                       
                                       
                                     (G=F)
                                  (H=G*0.05)
                                  (I=G*0.10)
                                       
1. APPLICATIONS (Not Applicable)
                                       
                                       
                                       
                                       
                                       
                                       
 
 
 
 
2. SURVEY AND STUDIES (Not Applicable)
                                       
                                       
                                       
                                       
                                       
                                       
 
 
 
 
3. REPORT REQUIREMENTS
                                       
                                       
                                       
                                       
                                       
                                       
 
 
 
 
A. Read Instructions
                                       1
                                       1
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
B. Required Activities
                                       
                                       
                                       
                                       
                                       
                                       
                                       0
                                       0
                                       0
                                       0
Initial performance test
                                      24
                                       1
                                      24
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Repeat performance test
                                      24
                                       1
                                      24
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
C. Create Information (Included in 3B)
                                       
                                       
                                       
                                       
                                       
                                       
 
 
 
 
D. Gather Existing Information (Included in 3E)
                                       
                                       
                                       
                                       
                                       
                                       
 
 
 
 
E. Write Report
                                       
                                       
                                       
                                       
                                       
                                       
 
 
 
 
Notification of construction or reconstruction
                                       2
                                       1
                                       2
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Notification of anticipated startup
                                       2
                                       1
                                       2
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Notification of actual startup
                                       2
                                       1
                                       2
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Notification of initial performance test
                                       2
                                       1
                                       2
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Report of performance test (Included in 3B)
                                       
                                       
                                       
                                       
                                       
                                       
 
 
 
 
Semiannual work practice reports
                                       8
                                       2
                                      16
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Subtotal for Reports
                                       
                                       
                                       
                                       
                                       
                                       
 
 
 
 
4. RECORDKEEPING REQUIREMENTS
                                       
                                       
                                       
                                       
                                       
                                       
 
 
 
 
Table B.10 Model Refinery  -  40 CFR Part 61, Subpart GGGa Supporting Statement Analysis (Cont.) [[1][,2][]]
                                  Burden item
                                      (A)
                                      (B)
                                      (C)
                                      (D)
                                      (E)
                                      (F)
                                      (G)
                                      (H)
                                      (I)
                                      (J)
                                       
        Person-hours per occurrence for SFI (from supporting statement)
    No. of occurrences per respondent per year (from supporting statement)
       Person-hours per respondent per year (from supporting statement)
           Person-hours per occurrence applicable to Model Refinery
              No. of occurrences for the Model Refinery per year
                 Person-hours for the Model Refinery per year
                            Technical Hours
(hr/yr)
                           Managerial Hours
(hr/yr)
                            Clerical Hours
(hr/yr)
  Total Cost ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr
                                       
                                       
                                       
                                    (C=AxB)
                                       
                                       
                                       
                                     (G=F)
                                  (H=G*0.05)
                                  (I=G*0.10)
                                       
A. Read Instructions (Included in 3A)
                                       
                                       
                                       
                                       
                                       
                                       
 
 
 
 
B. Plan Activities (Included in 3B)
                                       
                                       
                                       
                                       
                                       
                                       
 
 
 
 
C. Implement Activities (Included in 3B)
                                       
                                       
                                       
                                       
                                       
                                       
 
 
 
 
D. Develop Record System (Not Applicable)
                                       
                                       
                                       
                                       
                                       
                                       
 
 
 
 
E. Time to Enter Information
                                       
                                       
                                       
                                       
                                       
                                       
 
 
 
 
Records of operating parameters at large refineries 
                                      0.4
                                      365
                                      148
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Records of operating parameters for small refineries
                                     0.42
                                      365
                                      153
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
F. Train Personnel (Not Applicable)
                                       
                                       
                                       
                                       
                                       
                                       
 
 
 
 
G. Audits (Not Applicable)
                                       
                                       
                                       
                                       
                                       
                                       
 
 
 
 
Subtotal for Recordkeeping
                                       
                                       
                                       
                                       
                                       
                                       
 
 
 
 
5. Total Annual Labor Hours and Cost (rounded)
                                       
                                       
                                       
                                       
                                       
                                       
 
 
 
 
TOTAL with Paper Reporting Paper
                                       0
TOTAL with Electronic Reporting
                                       0
TOTAL Record Keeping
                                       0
[1] The referenced supporting statement contains several footnotes associated with the original burden estimate. Please refer to the original supporting statement, included in the rulemaking docket. 

[2] Burden analysis for Subpart GGG is zero since units at the model refinery are also subject to Subpart VV and are complying with Subpart GGG by complying with Subpart VV. Burden is accounted for in Subpart VV. 

                                       
Table B.11 Model Refinery  -  40 CFR Part 63, Subpart R Supporting Statement Analysis [[1]]
                                  Burden item
                                      (A)
                                      (B)
                                      (C)
                                      (D)
                                      (E)
                                      (F)
                                      (G)
                                      (H)
                                      (I)
                                      (J)
                                       
        Person-hours per occurrence for SFI (from supporting statement)
    No. of occurrences per respondent per year (from supporting statement)
       Person-hours per respondent per year (from supporting statement)
           Person-hours per occurrence applicable to Model Refinery
              No. of occurrences for the Model Refinery per year
                 Person-hours for the Model Refinery per year
                            Technical Hours
(hr/yr)
                           Managerial Hours
(hr/yr)
                            Clerical Hours
(hr/yr)
  Total Cost ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr
                                       
                                       
                                       
                                    (C=AxB)
                                       
                                       
                                       
                                     (G=F)
                                  (H=G*0.05)
                                  (I=G*0.10)
                                       
1.  APPLICATIONS
                                      N/A
                                      N/A
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
2.  SURVEY AND STUDIES
                                      N/A
                                      N/A
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
3.  ACQUISITION, INSTALLATION, AND UTILIZATION OF TECHNOLOGY AND SYSTEMS
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
4. REPORTING REQUIREMENTS
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
A.  Read Instructions
                                       1
                                       1
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
B.  Required Activities
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Initial performance test
                                      175
                                       1
                                      175
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Repeat of performance test
                                      175
                                       1
                                      175
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Storage tank seal/seal gap inspections tanks certification
                                      16
                                       1
                                      16
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Annual testing certification of area source compliance status
                                       1
                                       1
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
C.  Create Information
      ------------------------Included in 4B----------------------------
                                       
                                       
                                       
                                       
                                       
                                       
                                       
D.  Gather Existing Information
      ------------------------Included in 4B----------------------------
                                       
                                       
                                       
                                       
                                       
                                       
                                       
E.  Write Report
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Notification of applicability
                                       3
                                       1
                                       3
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Notification of construction/reconstruction/modification
                                       2
                                       1
                                       2
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Notification of actual startup
                                       2
                                       1
                                       2
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Notification of performance test
                                       2
                                       1
                                       2
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Notification of CEMS performance evaluation
                                       2
                                       1
                                       2
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Notification of area source compliance status
                                       1
                                       1
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Report of performance test 
      ------------------------Included in 4B----------------------------
                                       
                                       
                                       
                                       
                                       
                                       
                                       


Table B.11 Model Refinery  -  40 CFR Part 63, Subpart R Supporting Statement Analysis (Cont.) [[1]]
                                  Burden item
                                      (A)
                                      (B)
                                      (C)
                                      (D)
                                      (E)
                                      (F)
                                      (G)
                                      (H)
                                      (I)
                                      (J)
                                       
        Person-hours per occurrence for SFI (from supporting statement)
    No. of occurrences per respondent per year (from supporting statement)
       Person-hours per respondent per year (from supporting statement)
           Person-hours per occurrence applicable to Model Refinery
              No. of occurrences for the Model Refinery per year
                 Person-hours for the Model Refinery per year
                            Technical Hours
(hr/yr)
                           Managerial Hours
(hr/yr)
                            Clerical Hours
(hr/yr)
  Total Cost ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr
                                       
                                       
                                       
                                    (C=AxB)
                                       
                                       
                                       
                                     (G=F)
                                  (H=G*0.05)
                                  (I=G*0.10)
                                       
Semiannual compliance reports bulk terminals major sources
                                      10
                                       2
                                      20
                                      10
                                       2
                                      20
                                      20
                                       1
                                       2
                                   1,854.28
Semiannual compliance reports pipeline breakout major sources
                                       8
                                       2
                                      16
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
5.  RECORDKEEPING REQUIREMENTS
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
A.  Read Instructions
        ------------------------Included in 4A------------------------
                                       
                                       
                                       
                                       
                                       
                                       
                                       
B.  Plan Activities
         ------------------------Included in 4B and 5C---------------
                                       
                                       
                                       
                                       
                                       
                                       
                                       
C.  Implement Activities
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Gasoline terminals:
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
File cargo tank inspection records
                                      0.5
                                      26
                                      13
                                     0.50
                                      26
                                      13
                                      13
                                     0.65
                                      1.3
                                   1,205.28
Update cargo tank inspection records
                                       6
                                       1
                                       6
                                       6
                                       1
                                       6
                                       6
                                      0.3
                                      0.6
                                    556.28
Cross-check cargo tank inspection file
                                       6
                                      26
                                      156
                                       6
                                      26
                                      156
                                      156
                                      7.8
                                     15.6
                                   14,463.38
Pipeline breakout stations
        ------------------------Included in 4B------------------------
                                       
                                       
                                       
                                       
                                       
                                       
                                       
D.  Develop Record System
                                       8
                                       1
                                       8
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
E.  Time to Enter Information  
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Record equipment subject to visual inspection requirements at pipeline breakout stations
                                       1
                                       1
                                       1
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Record equipment leaks data at bulk terminals
                                      0.1
                                       4
                                      0.4
                                    0[[3]]
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Record equipment leaks data at pipeline breakout stations
                                      0.1
                                      12
                                      1.2
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Record storage tank seal inspection results
                                       1
                                       1
                                       1
                                    0[[4]]
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Records of startups, shutdowns, malfunctions, etc.
                                       1
                                       4
                                       4
                                       1
                                       4
                                       4
                                       4
                                      0.2
                                      0.4
                                    370.86
Area source recordkeeping:
                                     0.25
                                      1.0
                                     0.25
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
F.  Time to train personnel
                                       1
                                       1
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0



Table B.11 Model Refinery  -  40 CFR Part 63, Subpart R Supporting Statement Analysis (Cont.) [[1]]
                                  Burden item
                                      (A)
                                      (B)
                                      (C)
                                      (D)
                                      (E)
                                      (F)
                                      (G)
                                      (H)
                                      (I)
                                      (J)
                                       
        Person-hours per occurrence for SFI (from supporting statement)
    No. of occurrences per respondent per year (from supporting statement)
       Person-hours per respondent per year (from supporting statement)
           Person-hours per occurrence applicable to Model Refinery
              No. of occurrences for the Model Refinery per year
                 Person-hours for the Model Refinery per year
                            Technical Hours
(hr/yr)
                           Managerial Hours
(hr/yr)
                            Clerical Hours
(hr/yr)
  Total Cost ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr
                                       
                                       
                                       
                                    (C=AxB)
                                       
                                       
                                       
                                     (G=F)
                                  (H=G*0.05)
                                  (I=G*0.10)
                                       
G. Time to adjust existing ways to comply with previously applicable requirements
                                      N/A
                                      N/A
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
H. Time to transmit information
        ------------------------Included in 5E-------------------------
                                       
                                       
                                       
                                       
                                       
                                       
                                       
I.  Time for audits:
                                      N/A
                                      N/A
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Bulk gasoline terminals
                                       6
                                       1
                                       6
                                       6
                                       1
                                       6
                                       6
                                      0.3
                                      0.6
                                    556.28
Pipeline breakout stations
                                       4
                                       1
                                       4
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
TOTAL with Paper Reporting Paper (Semiannual Compliance Reports)
                                     1,854
TOTAL with Electronic Reporting
                                       0
TOTAL Record Keeping (Sum of All Items under 5)
                                    17,152
[1] The referenced supporting statement contains several footnotes associated with the original burden estimate. Please refer to the original supporting statement, included in the rulemaking docket. 
[2] Model refinery does not include a pipeline breakout station. 
[3] Model refinery is not required to comply with equipment leak requirements under Subpart R. 
[4] Model refinery is not required to comply with storage vessel requirements under Subpart R. 
                                       

Table B.12 Model Refinery  -  40 CFR Part 60, Subpart XX Supporting Statement Analysis [[1][,2][]]
                                  Burden item
                                      (A)
                                      (B)
                                      (C)
                                      (D)
                                      (E)
                                      (F)
                                      (G)
                                      (H)
                                      (I)
                                      (J)
                                       
        Person-hours per occurrence for SFI (from supporting statement)
    No. of occurrences per respondent per year (from supporting statement)
       Person-hours per respondent per year (from supporting statement)
           Person-hours per occurrence applicable to Model Refinery
              No. of occurrences for the Model Refinery per year
                 Person-hours for the Model Refinery per year
                            Technical Hours
(hr/yr)
                           Managerial Hours
(hr/yr)
                            Clerical Hours
(hr/yr)
  Total Cost ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr
                                       
                                       
                                       
                                    (C=AxB)
                                       
                                       
                                       
                                     (G=F)
                                  (H=G*0.05)
                                  (I=G*0.10)
                                       
1.  Applications
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
2.  Survey and Studies
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
3.  Reporting requirements
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
     A.  Read instructions 
                                       1
                                       1
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
     B.  Required activities
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
        Initial performance tests
                                      60
                                       1
                                      60
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
        Repeat performance tests
                                      60
                                      0.2
                                      12
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
        Monitoring of operations and equipment [e]
                                    See 4E
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
     C.  Gather existing information
                                 See 3B and 4E
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
     D.  Write Report
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
        Notification of compliance status
                                       2
                                       1
                                       2
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
        Notification of actual startup
                                       2
                                       1
                                       2
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
        Notification of construction/modification
                                       2
                                       1
                                       2
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
        Notification of performance test
                                       2
                                       1
                                       2
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
        Reports of performance test results
                                    See 3B
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
        Operation and maintenance reports 
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
        Semiannual reports
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
  Subtotal  for Reporting  Requirements
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
4.  Recordkeeping requirements
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
     A.  Read instructions 
                                    See 3A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
     B.  Plan activities
                                    See 3B
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
     C.  Implement Activities 
                                    See 3B
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Table B.12 Model Refinery  -  40 CFR Part 60, Subpart XX Supporting Statement Analysis (Cont.) [[1][,2][]]
                                  Burden item
                                      (A)
                                      (B)
                                      (C)
                                      (D)
                                      (E)
                                      (F)
                                      (G)
                                      (H)
                                      (I)
                                      (J)
                                       
        Person-hours per occurrence for SFI (from supporting statement)
    No. of occurrences per respondent per year (from supporting statement)
       Person-hours per respondent per year (from supporting statement)
           Person-hours per occurrence applicable to Model Refinery
              No. of occurrences for the Model Refinery per year
                 Person-hours for the Model Refinery per year
                            Technical Hours
(hr/yr)
                           Managerial Hours
(hr/yr)
                            Clerical Hours
(hr/yr)
  Total Cost ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr
                                       
                                       
                                       
                                    (C=AxB)
                                       
                                       
                                       
                                     (G=F)
                                  (H=G*0.05)
                                  (I=G*0.10)
                                       
     D.  Develop record system
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
  E.  Time to enter and transmit information
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
   Records of startup, shutdown, malfunction
                                      1.5
                                      50
                                      75
                                      1.5
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
    Record of tank identification numbers
                                      0.1
                                     2,100
                                      210
                                      0.1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
   Leak detection records of monthly control equipment inspections
                                      0.1
                                      12
                                      1.2
                                      0.1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
    F.  Time to train personnel 
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
    G.  Time for audits
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
   Subtotal  for Recordkeeping Requirements  
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
TOTAL with Paper Reporting Paper
                                       0
TOTAL with Electronic Reporting
                                       0
TOTAL Record Keeping
                                       0
[1] The referenced supporting statement contains several footnotes associated with the original burden estimate. Please refer to the original supporting statement, included in the rulemaking docket. 
[2] Burden analysis for Subpart XX is zero since units are complying with Subpart XX by complying with Subpart CC and burden is accounted for in Subpart CC analysis. 
                                       

Table B.13 Model Refinery  -  40 CFR Part 63, Subpart Y Supporting Statement Analysis [[1]]
                                  Burden item
                                      (A)
                                      (B)
                                      (C)
                                      (D)
                                      (E)
                                      (F)
                                      (G)
                                      (H)
                                      (I)
                                      (J)
                                       
        Person-hours per occurrence for SFI (from supporting statement)
    No. of occurrences per respondent per year (from supporting statement)
       Person-hours per respondent per year (from supporting statement)
           Person-hours per occurrence applicable to Model Refinery
              No. of occurrences for the Model Refinery per year
                 Person-hours for the Model Refinery per year
                            Technical Hours
(hr/yr)
                           Managerial Hours
(hr/yr)
                            Clerical Hours
(hr/yr)
  Total Cost ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr
                                       
                                       
                                       
                                    (C=AxB)
                                       
                                       
                                       
                                     (G=F)
                                  (H=G*0.05)
                                  (I=G*0.10)
                                       
1.  Applications
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
2.  Survey and Studies
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
3.  Acquisition, Installation, and Utilization of Technology and Systems
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
4. Reporting Requirements
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
A. Read instructions
                                       8
                                       1
                                       8
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
B. Required activities
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Performance test (Method 25A)
                                      100
                                       1
                                      100
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Repeat of performance test
                                      100
                                       1
                                      100
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Leak check
                                      16
                                       1
                                      16
                                      16
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
Vapor tightness test
                                       8
                                       1
                                       8
                                       8
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
C. Create information
                             Included in 3B and 4E
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
D. Gather existing information
                             Included in 3B and 4E
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
E. Write report
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Initial notification of applicability
                                       4
                                       1
                                       4
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Notification of compliance status
                                Included in 3B
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Site-specific test plan
                                Included in 3B
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Notification of performance test
                                       2
                                       1
                                       2
                                    0[[3]]
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Report of HAP control Efficiency
                                       8
                                       1
                                       8
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
5. Recordkeeping Requirements
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
A. Read instructions
                                       1
                                       1
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
B. Plan activities
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
C. Implement activities
                                      16
                                       1
                                      16
                                      16
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Table B.13 Model Refinery  -  40 CFR Part 63, Subpart Y Supporting Statement Analysis (Cont.) [[1]]
                                  Burden item
                                      (A)
                                      (B)
                                      (C)
                                      (D)
                                      (E)
                                      (F)
                                      (G)
                                      (H)
                                      (I)
                                      (J)
                                       
        Person-hours per occurrence for SFI (from supporting statement)
    No. of occurrences per respondent per year (from supporting statement)
       Person-hours per respondent per year (from supporting statement)
           Person-hours per occurrence applicable to Model Refinery
              No. of occurrences for the Model Refinery per year
                 Person-hours for the Model Refinery per year
                            Technical Hours
(hr/yr)
                           Managerial Hours
(hr/yr)
                            Clerical Hours
(hr/yr)
  Total Cost ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr
                                       
                                       
                                       
                                    (C=AxB)
                                       
                                       
                                       
                                     (G=F)
                                  (H=G*0.05)
                                  (I=G*0.10)
                                       
D. Develop record system
                                      16
                                       1
                                      16
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
E. Time to enter information
                                       1
                                       1
                                       1
                                       1
                                       1
                                       1
                                       1
                                     0.05
                                      0.1
                                     92.71
F. Time to transmit or disclose information
                                     0.25
                                       1
                                     0.25
                                     0.25
                                       1
                                     0.25
                                     0.25
                                    0.0125
                                     0.025
                                     23.18
G. Time for audits
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
TOTAL with Paper Reporting Paper
                                       0
TOTAL with Electronic Reporting
                                       0
TOTAL Record Keeping (Sum of 5.E and 5.F)
                                      116
[1] The referenced supporting statement contains several footnotes associated with the original burden estimate. Please refer to the original supporting statement, included in the rulemaking docket. 
[2] Marine terminal at model refinery not subject to requirement. 
[3] One time performance test requirement. 
                                       

Table B.14 Model Refinery  -  40 CFR Part 63, Subpart UU Supporting Statement Analysis [[1]]
                                  Burden item
                                      (A)
                                      (B)
                                      (C)
                                      (D)
                                      (E)
                                      (F)
                                      (G)
                                      (H)
                                      (I)
                                      (J)
                                       
        Person-hours per occurrence for SFI (from supporting statement)
    No. of occurrences per respondent per year (from supporting statement)
       Person-hours per respondent per year (from supporting statement)
           Person-hours per occurrence applicable to Model Refinery
              No. of occurrences for the Model Refinery per year
                 Person-hours for the Model Refinery per year
                            Technical Hours
(hr/yr)
                           Managerial Hours
(hr/yr)
                            Clerical Hours
(hr/yr)
  Total Cost ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr
                                       
                                       
                                       
                                    (C=AxB)
                                       
                                       
                                       
                                     (G=F)
                                  (H=G*0.05)
                                  (I=G*0.10)
                                       
1. Applications
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
2. Survey and Studies
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
3. Acquisition, Installation, and Utilization of Technology and Systems  
                                      40
                                       1
                                      40
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
4. Reporting Requirements
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
A. Read instructions
                                       2
                                       1
                                       2
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
B. Required activities
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
  Initial Performance test 
                                      40
                                       1
                                      40
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
  Performance test
                                      40
                                       1
                                      40
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
  Startup, shutdown, malfunction  Plan
                                      40
                                       1
                                      40
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
  Operating, maintenance, and  monitoring plan
                                      40
                                       1
                                      40
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
C. Create information
                                    See 4B
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
D. Gather existing information
                                    See 4B
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
E. Write report
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
  Notification of construction/ reconstruction
                                       2
                                       1
                                       2
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
  Notification of actual startup
                                       2
                                       1
                                       2
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
  Notification of special compliance requirements
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
  Notification of performance  test
                                       2
                                       1
                                       2
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
  Notification of compliance Status
                                       4
                                       1
                                       4
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
  Extended compliance request  
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
  Report of performance test
                                    See 4B
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
  Semiannual compliance reports
                                      10
                                       2
                                      20
                                      10
                                       2
                                      20
                                      20
                                       1
                                       2
                                   1,854.28
Table B.14 Model Refinery  -  40 CFR Part 63, Subpart UU Supporting Statement Analysis (Cont.) [[1]]
                                  Burden item
                                      (A)
                                      (B)
                                      (C)
                                      (D)
                                      (E)
                                      (F)
                                      (G)
                                      (H)
                                      (I)
                                      (J)
                                       
        Person-hours per occurrence for SFI (from supporting statement)
    No. of occurrences per respondent per year (from supporting statement)
       Person-hours per respondent per year (from supporting statement)
           Person-hours per occurrence applicable to Model Refinery
              No. of occurrences for the Model Refinery per year
                 Person-hours for the Model Refinery per year
                            Technical Hours
(hr/yr)
                           Managerial Hours
(hr/yr)
                            Clerical Hours
(hr/yr)
  Total Cost ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr
                                       
                                       
                                       
                                    (C=AxB)
                                       
                                       
                                       
                                     (G=F)
                                  (H=G*0.05)
                                  (I=G*0.10)
                                       
5. Recordkeeping Requirements
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
A. Read instructions
                                    See 4A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
B. Plan activities
                                    See 4B
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
C. Implement activities
                                    See 4B
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
D. Develop record system
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
E. Time to enter information
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
    Records of operations  
                                       1
                                      52
                                      52
                                       1
                                      52
                                      52
                                      52
                                      2.6
                                      5.2
                                   4,821.13
F. Time to train personnel  
                                       4
                                       1
                                       4
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
G. Time to adjust existing ways to comply with previously applicable requirements  
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
H. Time to transmit or disclose Information
                                     0.25
                                       1
                                     0.25
                                     0.25
                                       1
                                     0.25
                                     0.25
                                    0.0125
                                     0.025
                                     23.18
I. Time for audits
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
TOTAL with Paper Reporting Paper (Semiannual Compliance Reports)
                                     1,854
TOTAL with Electronic Reporting
                                       0
TOTAL Record Keeping (Sum of 5.E, 5.F, and 5.H)
                                     4,844
[1] The referenced supporting statement contains several footnotes associated with the original burden estimate. Please refer to the original supporting statement, included in the rulemaking docket. 
[2] Performance test required for a significant process change - assumed requirement was not applicable.
                                       

                                       
                                       
                                  Appendix C:
                                       
 Burden Estimation and Supporting Statement Analysis  -  Model Chemical Plant

Table C.1 Model Chemical Plant  -  Summary of Potential Cost Savings Associated with 
               Uniform Standard Electronic Semiannual Reporting
                                     RULE
                               (A) Recordkeeping
              (B) Reporting Under Existing Rules Via Paper Methods
40 CFR Part 60, Subpart NNN 
                                     $858
                                     $556
40 CFR Part 60, Subpart Kb
                                     $528
                                     $590
40 CFR Part 63 Subpart YY, SS, and TT
                                    $11,682
                                    $1,669
40 CFR Part 63 Subpart G, H, and I (PV, EL, TR Only)
                                    $18,543
                                    $6,305
40 CFR Part 63 Subpart G (SV Only)
                                     $501
                                     $590
40 CFR Part 63 Subpart FFFF
                                    $18,728
                                    $6,305
                                    Total 
                                    $50,840
                                    $16,014
                                       
(C) Initial Electronic Start-up Cost for Proposed Uniform Standards
                                    $2,685
(D) Cost of Semiannual Electronic Reporting for proposed Uniform Standards
                                    $4,740
(E) Cost of Annual Electronic Reporting for proposed Uniform Standards
                                     $363
(F) Written to Electronic Reporting Burden Ratio (F=B/(D+2E)) [1]
                                     2.93
(G) Administrative Preparation for Electronic Data Entry  -  management of log in information, etc.
                                     $834
(H) Additional Reporting Requirement in Uniform Standards - Cost to semiannually report daily and operating block averages, required in §65.882(e).[[][2][]]
                                    $2,596
(I) Proposed Uniform Standards Reporting Costs for Electronic Semiannual and Written Annual Reports (I=D+(E*F)+G+H) [[3]]
                                    $9,235
(J) Potential Reporting Cost Savings Not Considering Initial Electronic Startup Costs for Proposed Uniform Standards (J=B-I)
                                    $6,779
(K) Savings Percentage - Reporting Cost Basis (K=J/B*100)
                                      42%
(L) Savings Percentage - Record Keeping and Reporting Cost Basis (L=J/(A+B)*100)
                                      10%
[[][1][]] Burden for annual reports multiplied by two because these are required semiannually under most existing rules. This ratio provides a general conversion between burden for electronic and written reports.
[[][2][]] Assumes 1 hour per process vent to upload data (14 process vents) entered twice a year for semiannual reporting for a total of 28 technical hours. Managerial and clerical hours were assumed to be five and ten percent of the annual technical hourly requirement, respectively.  Rates used are in Table 6 of memo.
[[][3][]] Annual reports are required in written format, therefore the burden associated with electronic annual reports was converted to burden for written reports (E*F).

                                       

Table C.2 Model Chemical Plant  -  40 CFR Part 63, Subpart NNN Supporting Statement Analysis [[1]]
                                  Burden item
                                      (A)
                                      (B)
                                      (C)
                                      (D)
                                      (E)
                                      (F)
                                      (G)
                                      (H)
                                      (I)
                                       
        Person-hours per occurrence for SFI (from supporting statement)
    No. of occurrences per respondent per year (from supporting statement)
        Person-hours per occurrence applicable to Model Chemical Plant
           No. of occurrences for the Model Chemical Plant per year
              Person-hours for the Model Chemical Plant per year
                            Technical Hours
(hr/yr)
                           Managerial Hours
(hr/yr)
                            Clerical Hours
(hr/yr)
  Total Cost ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr
                                       
                                       
                                       
                                       
                                       
                                       
                                     (F=E)
                                  (G=F*0.05)
                                  (H=F*0.10)
                                       
1. Applications
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
2. Survey and Studies
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
3. Reporting Requirements
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
A. Read Instructions
                                       1
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
B. Required Activities
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Initial Performance Test Report
                                      60
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Repeat Performance Test Report
                                      60
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
C. Write Report
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Notification of Construction/Modification
                                       2
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
  Notification of Actual Startup
                                       1
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
  Notification of Initial Performance Test
                                       2
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
  Semiannual Report
                                       3
                                       2
                                       3
                                       2
                                       6
                                       6
                                      0.3
                                      0.6
                                    556.28
Total Annual Responses ()
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
4. Recordkeeping Requirements
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Record of Operating Parameters for Control Devices
                                       1
                                      12
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Records of Operating Conditions Exceeding Last Performance Test
                                       1
                                       8
                                       1
                                       8
                                       8
                                       8
                                      0.4
                                      0.8
                                    741.71
Records of Startup, Shutdown, Malfunction, etc.
                                     0.25
                                       5
                                     0.25
                                       5
                                     1.25
                                     1.25
                                    0.0625
                                     0.125
                                    115.89
TOTAL with Paper Reporting Paper (Sum of Item 3.C)
                                      556
TOTAL with Electronic Reporting
                                       0
TOTAL Record Keeping (Sum of Item 4)
                                      858
[1] The referenced supporting statement contains several footnotes associated with the original burden estimate. Please refer to the original supporting statement, included in the rulemaking docket. 



[2] Assumed the model chemical plant currently complies with 40 CFR 60 Subpart NNN by maintaining a TRE greater than 8.0 through the use of two condensers and a scrubber. By 40 CFR 60.662(c)(4) each affected facility that has a total resource effectiveness index value greater than 8.0 is exempt from all provisions of this subpart except for 60.662 (standards), 60.664(d),(e),and(f) (Test Methods and Procedures), and 60.665(h) and (l) (Record keeping and reporting). Records of operating parameters are not included in (h) or (l).
Table C.3 Model Chemical Plant  -  40 CFR Part 63, Subpart RRR Supporting Statement Analysis [[1][,2][]]
                                  Burden item
                                      (A)
                                      (B)
                                      (C)
                                      (D)
                                      (E)
                                      (F)
                                      (G)
                                      (H)
                                      (I)
                                       
        Person-hours per occurrence for SFI (from supporting statement)
    No. of occurrences per respondent per year (from supporting statement)
        Person-hours per occurrence applicable to Model Chemical Plant
           No. of occurrences for the Model Chemical Plant per year
              Person-hours for the Model Chemical Plant per year
                            Technical Hours
(hr/yr)
                           Managerial Hours
(hr/yr)
                            Clerical Hours
(hr/yr)
  Total Cost ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr
                                       
                                       
                                       
                                       
                                       
                                       
                                     (F=E)
                                  (G=F*0.05)
                                  (H=F*0.10)
                                       
1. Applications
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
2. Survey and Studies
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
3. Reporting Requirements
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
A. Read Instructions
                                       1
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
B. Required Activities
                                      60
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Initial Performance Test Report
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Repeat Performance Test Report
                                      60
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
C. Write Report
                                       2
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Notification of Construction/
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
             Modification
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
  Notification of Actual Startup
                                       1
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
  Notification of Initial Performance Test
                                       2
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
  Semiannual Report
                                       3
                                       2
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Total Annual Responses ()
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
4. Recordkeeping Requirements
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Record of Operating Parameters for Control Devices
                                       1
                                      12
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Records of Operating Conditions Exceeding Last Performance Test
                                       1
                                       8
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Records of Startup, Shutdown, Malfunction, etc.
                                     0.25
                                       5
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0


Table C.3 Model Chemical Plant  -  40 CFR Part 63, Subpart RRR Supporting Statement Analysis (Cont.) [[1][,2][]]
                                  Burden item
                                      (A)
                                      (B)
                                      (C)
                                      (D)
                                      (E)
                                      (F)
                                      (G)
                                      (H)
                                      (I)
                                       
        Person-hours per occurrence for SFI (from supporting statement)
    No. of occurrences per respondent per year (from supporting statement)
        Person-hours per occurrence applicable to Model Chemical Plant
           No. of occurrences for the Model Chemical Plant per year
              Person-hours for the Model Chemical Plant per year
                            Technical Hours
(hr/yr)
                           Managerial Hours
(hr/yr)
                            Clerical Hours
(hr/yr)
  Total Cost ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr
                                       
                                       
                                       
                                       
                                       
                                       
                                     (F=E)
                                  (G=F*0.05)
                                  (H=F*0.10)
                                       
TOTAL with Paper Reporting Paper
                                       0
TOTAL with Electronic Reporting
                                       0
TOTAL Record Keeping
                                       0
[1] The referenced supporting statement contains several footnotes associated with the original burden estimate. Please refer to the original supporting statement, included in the rulemaking docket. 


[2] Process vent is subject to 40 CFR Part 60, Subpart RRR; however, pursuant to 40 CFR 60.700(c)(5), VOC emissions from the process tank vent D285, shall be considered in compliance with the provisions of Subpart RRR because the vent stream is routed to a distillation unit (C-650) subject to 40 CFR 60, Subpart NNN and has no other releases to the air except for a pressure relief valve. Therefore, all burden is accounted for under Subpart NNN. 
                                       

Table C.4 Model Chemical Plant  -  40 CFR Part 63, Subpart Kb Supporting Statement Analysis [[1]]
                                 Burden item 
                                      (A)
                                      (B)
                                      (C)
                                      (D)
                                      (E)
                                      (F)
                                      (G)
                                      (H)
                                      (I)

        Person-hours per occurrence for SFI (from supporting statement)
    No. of occurrences per respondent per year (from supporting statement)
        Person-hours per occurrence applicable to Model Chemical Plant 
           No. of occurrences for the Model Chemical Plant per year
              Person-hours for the Model Chemical Plant per year
                            Technical Hours
(hr/yr)
                           Managerial Hours
(hr/yr)
                            Clerical Hours
(hr/yr)
  Total Cost ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr

                                       
                                       
                                       
                                       
                                       
                                     (F=E)
                                  (G=F*0.05)
                                  (H=F*0.10)
                                       
1. Applications
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
2. Surveys and Studies
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
3. Reporting Requirements
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
A. Read Instruction
                                       1
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
B. Required Activities 
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
One-Time Only Requirements
                                       2
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Notification of Start of Construction
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Notification of Actual Startup
                                       2
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Notification of Physical or Operational Changes
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Notification of Malfunction
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Notification of Initial Inspection
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
IFR Internal Inspection
                                       2
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
EFR Gap Measurement
                                       2
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
    Initial Inspection Report
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
IFR Internal Inspection Report
                                      12
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
EFR 2nd Seal Gap Measurement
                                       8
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
EFR 1st Seal Gap Measurement
                                      12
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
CVS Operating Plan Report 
                                       8
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Repeat Requirements
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Internal IFR Inspection
                                      12
                                       1
                                      12
                                   0.2[[2]]
                                      2.4
                                      2.4
                                     0.12
                                     0.24
                                     66.75
Table C.4 Model Chemical Plant  -  40 CFR Part 63, Subpart Kb Supporting Statement Analysis (Cont.) [[1]]
                                 Burden item 
                                      (A)
                                      (B)
                                      (C)
                                      (D)
                                      (E)
                                      (F)
                                      (G)
                                      (H)
                                      (I)

        Person-hours per occurrence for SFI (from supporting statement)
    No. of occurrences per respondent per year (from supporting statement)
        Person-hours per occurrence applicable to Model Chemical Plant 
           No. of occurrences for the Model Chemical Plant per year
              Person-hours for the Model Chemical Plant per year
                            Technical Hours
(hr/yr)
                           Managerial Hours
(hr/yr)
                            Clerical Hours
(hr/yr)
  Total Cost ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr

                                       
                                       
                                       
                                       
                                       
                                     (F=E)
                                  (G=F*0.05)
                                  (H=F*0.10)
                                       
Visual IFR Inspection
                                       8
                                       1
                                       8
                                       1
                                       8
                                       8
                                      0.4
                                      0.8
                                    222.51
Report of IFR Failure
                                       2
                                       1
                                       2
                                    0[[3]]
                                       0
                                       0
                                       0
                                       0
                                     0.00
Notification of Delay of Repair or Emptying for IFR
                                       4
                                       1
                                       4
                                    0[[3]]
                                       0
                                       0
                                       0
                                       0
                                     0.00
EFR 2nd Seal Gap Measure Report
                                       8
                                       1
                                       8
                                    1[[4]]
                                       8
                                       8
                                      0.4
                                      0.8
                                    222.51
EFR 1st Seal Gap Measure Report
                                      12
                                       1
                                      12
                                   0.2[[5]]
                                      2.4
                                      2.4
                                     0.12
                                     0.24
                                     66.75
Notification of Refill
                                       2
                                       1
                                       2
                                   0.2[[6]]
                                      0.4
                                      0.4
                                     0.02
                                     0.04
                                     11.13
       Number of Responses 
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
 4.RECORDKEEPING REQUIREMENTS
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
 A.. Read Instructions
                                       1
                                       1
                                       1
                                       1
                                       1
                                       1
                                     0.05
                                      0.1
                                     27.81
 B. Gather and Record Information 
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
i.  Vessel Volumes, Liquid Vapor Pressure, flares
                                       8
                                       1
                                       8
                                    0[[7]]
                                       0
                                       0
                                       0
                                       0
                                       0
 ii.  113b(a) inspection 
                                      12
                                       1
                                      12
                                    1[[8]]
                                      12
                                      12
                                      0.6
                                      1.2
                                    333.77
iii. 113b(b) gap measurement for Secondary Seal
                                      12
                                       1
                                       5
                                    1[[9]]
                                       5
                                       5
                                     0.25
                                      0.5
                                    139.07
iii. 113b(b) gap measurement for Primary Seal
                                      12
                                       1
                                       5
                                   0.2[[5]]
                                       1
                                       1
                                     0.05
                                      0.1
                                     27.81
C. Develop Record System 
                                      10
                                       1
                                       0
                                       
                                       
                                       
                                       
                                       
                                       
D. Time to Enter Information - CVS Parameter Records
                                       2
                                      52
                                       2
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
F. Train Personnel
                                      N/A
                                       
                                      N/A
.
 
 
 
 
 
G. Audits
                                      N/A
                                       
                                      N/A
 
 
 
 
 
 
Table C.4 Model Chemical Plant  -  40 CFR Part 63, Subpart Kb Supporting Statement Analysis (Cont.) [[1]]
                                 Burden item 
                                      (A)
                                      (B)
                                      (C)
                                      (D)
                                      (E)
                                      (F)
                                      (G)
                                      (H)
                                      (I)

        Person-hours per occurrence for SFI (from supporting statement)
    No. of occurrences per respondent per year (from supporting statement)
        Person-hours per occurrence applicable to Model Chemical Plant 
           No. of occurrences for the Model Chemical Plant per year
              Person-hours for the Model Chemical Plant per year
                            Technical Hours
(hr/yr)
                           Managerial Hours
(hr/yr)
                            Clerical Hours
(hr/yr)
  Total Cost ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr

                                       
                                       
                                       
                                       
                                       
                                     (F=E)
                                  (G=F*0.05)
                                  (H=F*0.10)
                                       
TOTAL with Paper Reporting Paper (Sum of Repeat Requirements Under 3.B)
                                      590
TOTAL with Electronic Reporting
                                       0
TOTAL Record Keeping (Sum of Items 4.A and 4.B)
                                      528
[1] The referenced supporting statement contains several footnotes associated with the original burden estimate.  Please refer to the original supporting statement, included in the rulemaking docket. 
[2] Original supporting statement indicate 20% of IFRs will be inspected, because inspections are conducted every 5 years.  To account for the inspections for the one IFR tank we have included 20% of total hours for an annual average.
[3] Assumed no IFR failures at model facility. 
[4] One external floating roof (EFR) tank subject to Part 60, Subpart Kb. 
[5] This measurement occurs only once every 5 years, therefore, the occurrence rate is 1/5 the number of occurrences for the secondary seal measurement. 
[6] Assumed 20% per year will do refill notification.
[7] This burden estimate from the original supporting statement includes requirement in Kb provision in 60.115(b)(2) to keep a record of all periods of operation during which the flare pilot flame is absent. As none of the model chemical plant storage tanks are controlled with a closed vent system and flare to comply with §60.112b, the burden associated with complying with this provision does not apply.
[8] This requirement is for IFR tanks. The original supporting statement indicated that the average facility has 12.5 tanks with 75% IFR or 12 hours for 9.4 tanks (1.3 hours per tank).  The model chemical facility has 1 IFR subject to Kb. 
[9] Original supporting statement indicated average facility has 12.5 tanks of which 20% (2.5 tanks) are EFR, therefore, 3.2 hours per tank - the model chemical plant has 1 Kb EFR, therefore, assumed 3.2 hours. Also assumed that 70% of the cost attributable to performing the gap measurements (so only 30% is associated with the record burden for this line item.)
                                       

Table C.5 Model Chemical Plant  -  40 CFR Part 63, Subpart G Supporting Statement Analysis [[1][,2][]]
                                 Burden item 
                                      (A)
                                      (B)
                                      (C)
                                      (D)
                                      (E)
                                      (F)
                                      (G)
                                      (H)
                                      (I)

        Person-hours per occurrence for SFI (from supporting statement)
    No. of occurrences per respondent per year (from supporting statement)
        Person-hours per occurrence applicable to Model Chemical Plant 
           No. of occurrences for the Model Chemical Plant per year
              Person-hours for the Model Chemical Plant per year
                            Technical Hours
(hr/yr)
                           Managerial Hours
(hr/yr)
                            Clerical Hours
(hr/yr)
  Total Cost ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr

                                       
                                       
                                       
                                       
                                       
                                     (F=E)
                                  (G=F*0.05)
                                  (H=F*0.10)
                                       
1. Applications
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
2. Surveys and Studies
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
3. Reporting Requirements
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
A. Read Instruction
                                       1
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
B. Required Activities 
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
One-Time Only Requirements
                                       2
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Notification of Start of Construction
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Notification of Actual Startup
                                       2
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Notification of Physical or Operational Changes
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Notification of Malfunction
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Notification of Initial Inspection
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
IFR Internal Inspection
                                       2
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
EFR Gap Measurement
                                       2
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
    Initial Inspection Report
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
IFR Internal Inspection Report
                                      12
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
EFR 2nd Seal Gap Measurement
                                       8
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
EFR 1st Seal Gap Measurement
                                      12
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
CVS Operating Plan Report 
                                       8
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Repeat Requirements
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Internal IFR Inspection
                                      12
                                       1
                                      12
                                   0.2[[3]]
                                      2.4
                                      2.4
                                     0.12
                                     0.24
                                     66.75
Table C.5 Model Chemical Plant  -  40 CFR Part 63, Subpart G Supporting Statement Analysis (Cont.) [[1][,2][]]
                                 Burden item 
                                      (A)
                                      (B)
                                      (C)
                                      (D)
                                      (E)
                                      (F)
                                      (G)
                                      (H)
                                      (I)

        Person-hours per occurrence for SFI (from supporting statement)
    No. of occurrences per respondent per year (from supporting statement)
        Person-hours per occurrence applicable to Model Chemical Plant 
           No. of occurrences for the Model Chemical Plant per year
              Person-hours for the Model Chemical Plant per year
                            Technical Hours
(hr/yr)
                           Managerial Hours
(hr/yr)
                            Clerical Hours
(hr/yr)
  Total Cost ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr

                                       
                                       
                                       
                                       
                                       
                                     (F=E)
                                  (G=F*0.05)
                                  (H=F*0.10)
                                       
Visual IFR Inspection
                                       8
                                       1
                                       8
                                       1
                                       8
                                       8
                                      0.4
                                      0.8
                                    222.51
Report of IFR Failure
                                       2
                                       1
                                       2
                                    0[[4]]
                                       0
                                       0
                                       0
                                       0
                                     0.00
Notification of Delay of Repair or Emptying for IFR
                                       4
                                       1
                                       0
                                    0[[4]]
                                       0
                                       0
                                       0
                                       0
                                     0.00
EFR 2nd Seal Gap Measure Report
                                       8
                                       1
                                       8
                                    1[[5]]
                                       8
                                       8
                                      0.4
                                      0.8
                                    222.51
EFR 1st Seal Gap Measure Report
                                      12
                                       1
                                      12
                                   0.2[[6]]
                                      2.4
                                      2.4
                                     0.12
                                     0.24
                                     66.75
Notification of Refill
                                       2
                                       1
                                       2
                                   0.2[[7]]
                                      0.4
                                      0.4
                                     0.02
                                     0.04
                                     11.13
       Number of Responses 
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
 4.RECORDKEEPING REQUIREMENTS
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
 A.. Read Instructions
                                       1
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                     0.00
 B. Gather and Record Information 
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
i.  Vessel Volumes, Liquid Vapor Pressure, flares
                                       8
                                       1
                                       8
                                    0[[8]]
                                       0
                                       0
                                       0
                                       0
                                     0.00
 ii.  113b(a) inspection 
                                      12
                                       1
                                      12
                                    1[[9]]
                                      12
                                      12
                                      0.6
                                      1.2
                                    333.77
iii. 113b(b) gap measurement for Secondary Seal
                                      12
                                       1
                                       5
                                    1[[10]]
                                       5
                                       5
                                     0.25
                                      0.5
                                    139.07
iii. 113b(b) gap measurement for Primary Seal
                                      12
                                       1
                                       5
                                   0.2[[6]]
                                       1
                                       1
                                     0.05
                                      0.1
                                     27.81
C. Develop Record System 
                                      10
                                       1
                                       0
                                       
                                       
                                       
                                       
                                       
                                       
D. Time to Enter Information - CVS Parameter Records
                                       2
                                      52
                                       2
                                       0
                                       0
                                       0
                                       0
                                       0
                                     0.00
F. Train Personnel
                                      N/A
                                       
                                      N/A
.
 
 
 
 
 
G. Audits
                                      N/A
                                       
                                      N/A
 
 
 
 
 
 
Table C.5 Model Chemical Plant  -  40 CFR Part 63, Subpart G Supporting Statement Analysis (Cont.) [[1][,2][]]
                                 Burden item 
                                      (A)
                                      (B)
                                      (C)
                                      (D)
                                      (E)
                                      (F)
                                      (G)
                                      (H)
                                      (I)

        Person-hours per occurrence for SFI (from supporting statement)
    No. of occurrences per respondent per year (from supporting statement)
        Person-hours per occurrence applicable to Model Chemical Plant 
           No. of occurrences for the Model Chemical Plant per year
              Person-hours for the Model Chemical Plant per year
                            Technical Hours
(hr/yr)
                           Managerial Hours
(hr/yr)
                            Clerical Hours
(hr/yr)
  Total Cost ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr

                                       
                                       
                                       
                                       
                                       
                                     (F=E)
                                  (G=F*0.05)
                                  (H=F*0.10)
                                       
TOTAL with Paper Reporting Paper (Sum of Repeat Requirements Under 3.B)
                                      590
TOTAL with Electronic Reporting
                                       0
TOTAL Record Keeping (Sum of Items 4.A and 4.B)
                                      501
[1] The referenced supporting statement contains several footnotes associated with the original burden estimate.  Please refer to the original supporting statement, included in the rulemaking docket. 
[2] Original Subpart G supporting statement was unavailable for the analysis; therefore, Subpart Kb was used to estimate the burden under Subpart G.
[3] Original supporting statement indicate 20% of IFRs will be inspected, because inspections are conducted every 5 years.  To account for the inspections for the one IFR tank we have included 20% of total hours for an annual average.
[4] Assumed no IFR failures at model facility. 
[5] One external floating roof (EFR) tank subject to Part 60, Subpart G. 
[6] This measurement occurs only once every 5 years, therefore, the occurrence rate is 1/5 the number of occurrences for the secondary seal measurement. 
[7] Assumed 20% per year will do refill notification.
[8] This burden estimate from the original supporting statement includes requirement in Kb provision in 60.115(b)(2) to keep a record of all periods of operation during which the flare pilot flame is absent. As none of the model chemical plant storage tanks are controlled with a closed vent system and flare to comply with §60.112b, the burden associated with complying with this provision does not apply.
[9] This requirement is for IFR tanks. The original supporting statement indicated that the average facility has 12.5 tanks with 75% IFR or 12 hours for 9.4 tanks (1.3 hours per tank). The model chemical facility has 1 IFR subject to Kb. 
[10] Original supporting statement indicated average facility has 12.5 tanks of which 20% (2.5 tanks) are EFR, therefore, 3.2 hours per tank - the model chemical plant has 1 Kb EFR, therefore, assumed 3.2 hours. Also assumed that 70% of the cost attributable to performing the gap measurements (so only 30% is associated with the record burden for this line item.)
                                       

Table C.6 Model Chemical Plant  -  40 CFR Part 63, Subpart YY, SS, and TT Supporting Statement Analysis [[1]]
                                 Burden item 
                                      (A)
                                      (B)
                                      (C)
                                      (D)
                                      (E)
                                      (F)
                                      (G)
                                      (H)
                                      (I)

        Person-hours per occurrence for SFI (from supporting statement)
    No. of occurrences per respondent per year (from supporting statement)
        Person-hours per occurrence applicable to Model Chemical Plant 
           No. of occurrences for the Model Chemical Plant per year
              Person-hours for the Model Chemical Plant per year
                            Technical Hours
(hr/yr)
                           Managerial Hours
(hr/yr)
                            Clerical Hours
(hr/yr)
  Total Cost ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr

                                       
                                       
                                       
                                       
                                       
                                     (F=E)
                                  (G=F*0.05)
                                  (H=F*0.10)
                                       
1.  Applications
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
2.  Survey and Studies
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
3.  Reporting Requirements 
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
  A.  Read Instructions
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
  Polycarbonated (PC) Production
                                       4
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
  Acrylic and Modacrylic Fibers (AMF) Production 
                                       4
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
  Acetal Resins (AR) Production
                                       4
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
  Hydrogen Fluoride (HF) Production
                                       4
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
  B.  Required Activities for PC, AMF, AR, & HF
                                Included in 4C
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
  C.  Create Information for PC, AMF, AR, & HF
                                Included in 4C
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
  D.  Gather existing information for PC, AMF, AR & HF
                                Included in 4C
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
  E.  Write report
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
    i  Initial requirements: notifications, initial                               compliance determination, performance tests 
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                PC Production
                                      52
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                AMF Production
                                      52
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                AR Production
                                      52
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                HF Production
                                      52
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
Table C.6 Model Chemical Plant  -  40 CFR Part 63, Subpart YY, SS, and TT Supporting Statement Analysis (Cont.) [[1]]
                                 Burden item 
                                      (A)
                                      (B)
                                      (C)
                                      (D)
                                      (E)
                                      (F)
                                      (G)
                                      (H)
                                      (I)

        Person-hours per occurrence for SFI (from supporting statement)
    No. of occurrences per respondent per year (from supporting statement)
        Person-hours per occurrence applicable to Model Chemical Plant 
           No. of occurrences for the Model Chemical Plant per year
              Person-hours for the Model Chemical Plant per year
                            Technical Hours
(hr/yr)
                           Managerial Hours
(hr/yr)
                            Clerical Hours
(hr/yr)
  Total Cost ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr

                                       
                                       
                                       
                                       
                                       
                                     (F=E)
                                  (G=F*0.05)
                                  (H=F*0.10)
                                       
    ii  Startup, Shutdown malfunction reports
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                PC Production
                                       2
                                       1
                                       2
                                       1
                                       2
                                       2
                                      0.1
                                      0.2
                                    185.43
                AMF Production
                                       2
                                       1
                                       0
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
                AR Production
                                       2
                                       1
                                       0
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
                HF Production
                                       2
                                       1
                                       0
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
    iii  Periodic reports
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                PC Production
                                       8
                                       2
                                       8
                                       2
                                      16
                                      16
                                      0.8
                                      1.6
                                   1,483.42
                AMF Production
                                       8
                                       2
                                       0
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
                AR Production
                                       8
                                       2
                                       0
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
                HF Production
                                       8
                                       2
                                       0
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
    iv  Leak detection and repair (LDAR) reports 
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                PC Production
                                       8
                                       2
                                       8
                                       2
                                      16
                                      16
                                      0.8
                                      1.6
                                   1,483.42
                AMF Production
                                       8
                                       2
                                       0
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
                AR Production
                                       8
                                       2
                                       0
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
                HF Production
                                       8
                                       2
                                       0
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
4.  Recordkeeping Requirements
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
  A.  Read Instructions for
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                PC Production
                                       4
                                       1
                                       0
                                    0[[3]]
                                       0
                                       0
                                       0
                                       0
                                       0
                AMF Production
                                       4
                                       1
                                       0
                                   0[[2,3]]
                                       0
                                       0
                                       0
                                       0
                                       0
                AR Production
                                       4
                                       1
                                       0
                                   0[[2,3]]
                                       0
                                       0
                                       0
                                       0
                                       0
Table C.6 Model Chemical Plant  -  40 CFR Part 63, Subpart YY, SS, and TT Supporting Statement Analysis (Cont.) [[1]]
                                 Burden item 
                                      (A)
                                      (B)
                                      (C)
                                      (D)
                                      (E)
                                      (F)
                                      (G)
                                      (H)
                                      (I)

        Person-hours per occurrence for SFI (from supporting statement)
    No. of occurrences per respondent per year (from supporting statement)
        Person-hours per occurrence applicable to Model Chemical Plant 
           No. of occurrences for the Model Chemical Plant per year
              Person-hours for the Model Chemical Plant per year
                            Technical Hours
(hr/yr)
                           Managerial Hours
(hr/yr)
                            Clerical Hours
(hr/yr)
  Total Cost ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr

                                       
                                       
                                       
                                       
                                       
                                     (F=E)
                                  (G=F*0.05)
                                  (H=F*0.10)
                                       
                HF Production
                                       4
                                       1
                                       0
                                   0[[2,3]]
                                       0
                                       0
                                       0
                                       0
                                       0
  B.  Plan Activities for
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                PC Production
                                      40
                                       1
                                       0
                                    0[[3]]
                                       0
                                       0
                                       0
                                       0
                                       0
                AMF Production
                                      40
                                       1
                                       0
                                   0[[2,3]]
                                       0
                                       0
                                       0
                                       0
                                       0
                AR Production
                                      40
                                       1
                                       0
                                   0[[2,3]]
                                       0
                                       0
                                       0
                                       0
                                       0
                HF Production
                                      40
                                       1
                                       0
                                   0[[2,3]]
                                       0
                                       0
                                       0
                                       0
                                       0
  C.  Implement Activities
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
    i   Material determinations
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                PC Production
                                      N/A
                                       
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                AMF Production
                                      N/A
                                       
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                AR Production
                                      N/A
                                       
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                HF Production
                                      N/A
                                       
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
    ii  Control equipment inspection
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
        a.  Tanks
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                PC Production
                                      N/A
                                       
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                AMF Production
                                       2
                                      12
                                       0
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
                AR Production
                                       2
                                      12
                                       0
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
                HF Production
                                      N/A
                                       
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
        b.  Closed-vent system
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                PC Production
                                       2
                                       2
                                       2
                                       2
                                       4
                                       4
                                      0.2
                                      0.4
                                    370.86
                AMF Production
                                       2
                                       2
                                       0
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
Table C.6 Model Chemical Plant  -  40 CFR Part 63, Subpart YY, SS, and TT Supporting Statement Analysis (Cont.) [[1]]
                                 Burden item 
                                      (A)
                                      (B)
                                      (C)
                                      (D)
                                      (E)
                                      (F)
                                      (G)
                                      (H)
                                      (I)

        Person-hours per occurrence for SFI (from supporting statement)
    No. of occurrences per respondent per year (from supporting statement)
        Person-hours per occurrence applicable to Model Chemical Plant 
           No. of occurrences for the Model Chemical Plant per year
              Person-hours for the Model Chemical Plant per year
                            Technical Hours
(hr/yr)
                           Managerial Hours
(hr/yr)
                            Clerical Hours
(hr/yr)
  Total Cost ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr

                                       
                                       
                                       
                                       
                                       
                                     (F=E)
                                  (G=F*0.05)
                                  (H=F*0.10)
                                       
                AR Production
                                       2
                                       2
                                       0
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
                HF Production
                                       2
                                       2
                                       0
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
    iii  Control equipment leak monitoring
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
        a.  Cover vented to control device
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                PC Production
                                       1
                                       2
                                       0
                                    0[[4]]
                                       0
                                       0
                                       0
                                       0
                                       0
                AMF Production
                                       1
                                       2
                                       0
                                   0[[2,4]]
                                       0
                                       0
                                       0
                                       0
                                       0
                AR Production
                                       1
                                       2
                                       0
                                   0[[2,4]]
                                       0
                                       0
                                       0
                                       0
                                       0
                HF Production
                                       1
                                       2
                                       0
                                   0[[2,4]]
                                       0
                                       0
                                       0
                                       0
                                       0
        b.  Closed-vent system
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                PC Production
                                       1
                                       2
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                     0.00
                AMF Production
                                       1
                                       2
                                    0[[2]]
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
                AR Production
                                       1
                                       2
                                    0[[2]]
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
                HF Production
                                       1
                                       2
                                    0[[2]]
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
    iv.  Control devices
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
        a.  Initial requirements design analysis, performance
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
             Test
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                PC Production
                                      80
                                       1
                                       0
                                    0[[3]]
                                       0
                                       0
                                       0
                                       0
                                       0
                AMF Production
                                      80
                                       1
                                       0
                                   0[[2,3]]
                                       0
                                       0
                                       0
                                       0
                                       0
                AR Production
                                      80
                                       1
                                       0
                                   0[[2,3]]
                                       0
                                       0
                                       0
                                       0
                                       0
                HF Production
                                      80
                                       1
                                       0
                                   0[[2,3]]
                                       0
                                       0
                                       0
                                       0
                                       0
Table C.6 Model Chemical Plant  -  40 CFR Part 63, Subpart YY, SS, and TT Supporting Statement Analysis (Cont.) [[1]]
                                 Burden item 
                                      (A)
                                      (B)
                                      (C)
                                      (D)
                                      (E)
                                      (F)
                                      (G)
                                      (H)
                                      (I)

        Person-hours per occurrence for SFI (from supporting statement)
    No. of occurrences per respondent per year (from supporting statement)
        Person-hours per occurrence applicable to Model Chemical Plant 
           No. of occurrences for the Model Chemical Plant per year
              Person-hours for the Model Chemical Plant per year
                            Technical Hours
(hr/yr)
                           Managerial Hours
(hr/yr)
                            Clerical Hours
(hr/yr)
  Total Cost ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr

                                       
                                       
                                       
                                       
                                       
                                     (F=E)
                                  (G=F*0.05)
                                  (H=F*0.10)
                                       
        b.  Operate and maintain CMS
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                PC Production
                                       8
                                      12
                                       8
                                      12
                                      96
                                      96
                                      4.8
                                      9.6
                                   8,900.54
                AMF Production
                                       8
                                      12
                                       0
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
                AR Production
                                       8
                                      12
                                       0
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
                HF Production
                                       8
                                      12
                                       0
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
    v.  LDAR Program
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
        a.  Initial requirement: Identify all effected streams
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                PC Production
                                      20
                                       1
                                       0
                                    0[[3]]
                                       0
                                       0
                                       0
                                       0
                                       0
                AMF Production
                                      20
                                       1
                                       0
                                   0[[2,3]]
                                       0
                                       0
                                       0
                                       0
                                       0
                AR Production
                                      20
                                       1
                                       0
                                   0[[2,3]]
                                       0
                                       0
                                       0
                                       0
                                       0
                HF Production
                                      20
                                       1
                                       0
                                   0[[2,3]]
                                       0
                                       0
                                       0
                                       0
                                       0
        b.  Perform monitoring/repairs
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                PC Production               
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                   1)  In-house
                                      0.1
                                     1,092
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                     0.00
                   2) Use of contractor support
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                AMF Production
                                      16
                                      12
                                       0
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
                AR Production
                                      16
                                      12
                                       0
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
                HF Production
                                      0.1
                                     1,092
                                       0
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
    vi.  Container vapor tightness certification
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                PC Production
                                      N/A
                                       
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
Table C.6 Model Chemical Plant  -  40 CFR Part 63, Subpart YY, SS, and TT Supporting Statement Analysis (Cont.) [[1]]
                                 Burden item 
                                      (A)
                                      (B)
                                      (C)
                                      (D)
                                      (E)
                                      (F)
                                      (G)
                                      (H)
                                      (I)

        Person-hours per occurrence for SFI (from supporting statement)
    No. of occurrences per respondent per year (from supporting statement)
        Person-hours per occurrence applicable to Model Chemical Plant 
           No. of occurrences for the Model Chemical Plant per year
              Person-hours for the Model Chemical Plant per year
                            Technical Hours
(hr/yr)
                           Managerial Hours
(hr/yr)
                            Clerical Hours
(hr/yr)
  Total Cost ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr

                                       
                                       
                                       
                                       
                                       
                                     (F=E)
                                  (G=F*0.05)
                                  (H=F*0.10)
                                       
                AMF Production
                                      N/A
                                       
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                AR Production
                                      N/A
                                       
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                HF Production
                                      N/A
                                       
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
  D.  Develop Record System
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
    i.  Develop startup, shutdown, malfunction plan
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                PC Production
                                      20
                                       1
                                       0
                                    0[[3]]
                                       0
                                       0
                                       0
                                       0
                                       0
                AMF Production
                                      20
                                       1
                                       0
                                   0[[2,3]]
                                       0
                                       0
                                       0
                                       0
                                       0
                AR Production
                                      20
                                       1
                                       0
                                   0[[2,3]]
                                       0
                                       0
                                       0
                                       0
                                       0
                HF Production
                                      20
                                       1
                                       0
                                   0[[2,3]]
                                       0
                                       0
                                       0
                                       0
                                       0
    ii.  Control equipment
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                PC Production
                                      16
                                       1
                                       0
                                    0[[3]]
                                       0
                                       0
                                       0
                                       0
                                       0
                AMF Production
                                      16
                                       1
                                       0
                                   0[[2,3]]
                                       0
                                       0
                                       0
                                       0
                                       0
                AR Production
                                      16
                                       1
                                       0
                                   0[[2,3]]
                                       0
                                       0
                                       0
                                       0
                                       0
                HF Production
                                      16
                                       1
                                       0
                                   0[[2,3]]
                                       0
                                       0
                                       0
                                       0
                                       0
    iii.  LDAR Program
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                PC Production
                                      40
                                       1
                                       0
                                    0[[3]]
                                       0
                                       0
                                       0
                                       0
                                       0
                AMF Production
                                      40
                                       1
                                       0
                                   0[[2,3]]
                                       0
                                       0
                                       0
                                       0
                                       0
                AR Production
                                      40
                                       1
                                       0
                                   0[[2,3]]
                                       0
                                       0
                                       0
                                       0
                                       0
                HF Production
                                      40
                                       1
                                       0
                                   0[[2,3]]
                                       0
                                       0
                                       0
                                       0
                                       0
 E.  Record Information (all information required by                 standard)
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
Table C.6 Model Chemical Plant  -  40 CFR Part 63, Subpart YY, SS, and TT Supporting Statement Analysis (Cont.) [[1]]
                                 Burden item 
                                      (A)
                                      (B)
                                      (C)
                                      (D)
                                      (E)
                                      (F)
                                      (G)
                                      (H)
                                      (I)

        Person-hours per occurrence for SFI (from supporting statement)
    No. of occurrences per respondent per year (from supporting statement)
        Person-hours per occurrence applicable to Model Chemical Plant 
           No. of occurrences for the Model Chemical Plant per year
              Person-hours for the Model Chemical Plant per year
                            Technical Hours
(hr/yr)
                           Managerial Hours
(hr/yr)
                            Clerical Hours
(hr/yr)
  Total Cost ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr

                                       
                                       
                                       
                                       
                                       
                                     (F=E)
                                  (G=F*0.05)
                                  (H=F*0.10)
                                       
    i.  Initial requirements: cover design, control device              design, and control equipment testing
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                PC Production
                                      17
                                       1
                                       0
                                    0[[3]]
                                       0
                                       0
                                       0
                                       0
                                       0
                AMF Production
                                      17
                                       1
                                       0
                                   0[[2,3]]
                                       0
                                       0
                                       0
                                       0
                                       0
                AR Production
                                      17
                                       1
                                       0
                                   0[[2,3]]
                                       0
                                       0
                                       0
                                       0
                                       0
                HF Production
                                      17
                                       1
                                       0
                                   0[[2,3]]
                                       0
                                       0
                                       0
                                       0
                                       0
    ii.  Control equipment inspection
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                PC Production
                                       1
                                       2
                                       1
                                       2
                                       2
                                       2
                                      0.1
                                      0.2
                                    185.43
                AMF Production
                                       1
                                       2
                                       0
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
                AR Production
                                       1
                                       2
                                       0
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
                HF Production
                                       1
                                       2
                                       0
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
    iii.  Control equipment monitoring
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                PC Production
                                       1
                                      52
                                       0
                                    0[[5]]
                                       0
                                       0
                                       0
                                       0
                                     0.00
                AMF Production
                                       1
                                      52
                                       0
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
                AR Production
                                       1
                                      52
                                       0
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
                HF Production
                                       1
                                      52
                                       0
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
     iv.  Control device CMS   
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                PC Production
                                       1
                                      12
                                       1
                                      12
                                      12
                                      12
                                      0.6
                                      1.2
                                   1,112.57
                AMF Production
                                       1
                                      12
                                       0
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
                AR Production
                                       1
                                      12
                                       0
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
Table C.6 Model Chemical Plant  -  40 CFR Part 63, Subpart YY, SS, and TT Supporting Statement Analysis (Cont.) [[1]]
                                 Burden item 
                                      (A)
                                      (B)
                                      (C)
                                      (D)
                                      (E)
                                      (F)
                                      (G)
                                      (H)
                                      (I)

        Person-hours per occurrence for SFI (from supporting statement)
    No. of occurrences per respondent per year (from supporting statement)
        Person-hours per occurrence applicable to Model Chemical Plant 
           No. of occurrences for the Model Chemical Plant per year
              Person-hours for the Model Chemical Plant per year
                            Technical Hours
(hr/yr)
                           Managerial Hours
(hr/yr)
                            Clerical Hours
(hr/yr)
  Total Cost ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr

                                       
                                       
                                       
                                       
                                       
                                     (F=E)
                                  (G=F*0.05)
                                  (H=F*0.10)
                                       
                HF Production
                                       1
                                      12
                                       0
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
    v.  LDAR program
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                PC Production
                                     0.02
                                     1,092
                                       1
                                       2
                                       2
                                       2
                                      0.1
                                      0.2
                                    185.43
                AMF Production               
                                       2
                                      12
                                       0
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
                AR Production
                                       2
                                      12
                                       0
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
                HF Production
                                     0.02
                                     1,092
                                       0
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
  F.  Time to Train Personnel
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
    i.  Material determination methods
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                PC Production
                                      N/A
                                       
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                AMF Production
                                      N/A
                                       
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                AR Production
                                      N/A
                                       
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                HF Production
                                      N/A
                                       
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
    ii.  Control equipment inspection and monitoring
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                PC Production
                                       8
                                       1
                                       1
                                       8
                                       8
                                       8
                                      0.4
                                      0.8
                                    741.71
                AMF Production
                                       8
                                       1
                                       0
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
               AR Production
                                       8
                                       1
                                       0
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
                HF Production
                                       8
                                       1
                                       0
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
    iii.  LDAR program
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                PC Production
                                       2
                                       1
                                       2
                                       1
                                       2
                                       2
                                      0.1
                                      0.2
                                    185.43
                AMF Production
                                       2
                                       1
                                       0
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
                AR Production
                                       2
                                       1
                                       0
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
Table C.6 Model Chemical Plant  -  40 CFR Part 63, Subpart YY, SS, and TT Supporting Statement Analysis (Cont.) [[1]]
                                 Burden item 
                                      (A)
                                      (B)
                                      (C)
                                      (D)
                                      (E)
                                      (F)
                                      (G)
                                      (H)
                                      (I)

        Person-hours per occurrence for SFI (from supporting statement)
    No. of occurrences per respondent per year (from supporting statement)
        Person-hours per occurrence applicable to Model Chemical Plant 
           No. of occurrences for the Model Chemical Plant per year
              Person-hours for the Model Chemical Plant per year
                            Technical Hours
(hr/yr)
                           Managerial Hours
(hr/yr)
                            Clerical Hours
(hr/yr)
  Total Cost ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr

                                       
                                       
                                       
                                       
                                       
                                     (F=E)
                                  (G=F*0.05)
                                  (H=F*0.10)
                                       
                HF Production
                                       2
                                       1
                                       0
                                    0[[2]]
                                       0
                                       0
                                       0
                                       0
                                       0
    iv.  Container leak tight method
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                PC Production
                                      N/A
                                       
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                AMF Production
                                      N/A
                                       
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                AR Production
                                      N/A
                                       
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                HF Production
                                      N/A
                                       
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
Subtotal Labor Burden
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
TOTAL with Paper Reporting Paper (Sum of Items Under 3.E)
                                     1,669
TOTAL with Electronic Reporting
                                       0
TOTAL Record Keeping (Sum of Items From 4.C.ii.b to 4.F.iii)
                                    11,682
[1] The referenced supporting statement contains several footnotes associated with the original burden estimate.  Please refer to the original supporting statement, included in the rulemaking docket. 
[2] Process unit not applicable to model chemical plant. 
[3] One time requirement.
[4] Cover not applicable to model chemical plant. 
[5] There are no weekly control equipment monitoring for model chemical plant.
                                       

Table C.7 Model Chemical Plant  -  40 CFR Part 63, Subpart FFFF Supporting Statement Analysis [[1]]
                                 Burden item 
                                      (A)
                                      (B)
                                      (D)
                                      (E)
                                      (F)
                                      (G)
                                      (H)
                                      (I)
                                      (J)

        Person-hours per occurrence for SFI (from supporting statement)
    No. of occurrences per respondent per year (from supporting statement)
        Person-hours per occurrence applicable to Model Chemical Plant 
           No. of occurrences for the Model Chemical Plant per year
              Person-hours for the Model Chemical Plant per year
                            Technical Hours
(hr/yr)
                           Managerial Hours
(hr/yr)
                            Clerical Hours
(hr/yr)
  Total Cost ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr

                                       
                                       
                                       
                                       
                                       
                                     (G=F)
                                  (H=G*0.05)
                                  (I=G*0.10)
                                       
1. Applications
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
2. Surveys and Studies
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
3. Reporting Requirements
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
a. Read rule and instructions
                                       1
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
b. Required Activities
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
i. Initial Performance Test - process vents
                                      480
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
ii. Initial Performance Test - wastewater
                                      160
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
iii. Initial CMS performance evaluation
                                      10
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
iv. Repeat Performance Test
                                      20
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
c. Create Information 
                                Included in 3e
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
d. Gather existing Information 
                                Included in 3e
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
e. Write Reports
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
i. Notification of Construction/Reconstruction
                                       2
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
ii. Notification of Actual Startup
                                       2
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
iii. Initial Notification
                                       2
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
iv. Emissions Averaging Plan
                                      40
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
v. Precompliance Report
                                      40
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
vii. Performance Test Notification
                                       2
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
viii. Notification of Initial CMS performance evaluation
                                       2
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
ix. Notification of Compliance Status
                                       
                                       
                                       
                                       
                                       
                                       0
                                       0
                                       0
                                       0
Table C.7 Model Chemical Plant  -  40 CFR Part 63, Subpart FFFF Supporting Statement Analysis (Cont.) [[1]]
                                 Burden item 
                                      (A)
                                      (B)
                                      (D)
                                      (E)
                                      (F)
                                      (G)
                                      (H)
                                      (I)
                                      (J)

        Person-hours per occurrence for SFI (from supporting statement)
    No. of occurrences per respondent per year (from supporting statement)
        Person-hours per occurrence applicable to Model Chemical Plant 
           No. of occurrences for the Model Chemical Plant per year
              Person-hours for the Model Chemical Plant per year
                            Technical Hours
(hr/yr)
                           Managerial Hours
(hr/yr)
                            Clerical Hours
(hr/yr)
  Total Cost ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr

                                       
                                       
                                       
                                       
                                       
                                     (G=F)
                                  (H=G*0.05)
                                  (I=G*0.10)
                                       
a. With performance test
                                      80
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
b. W/O performance test
                                      120
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
x. Notification of Physical/ Operational Change
                                       8
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
xi. Semiannual Summary Report
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
a. No Deviations
                                       8
                                       2
                                       8
                                       0
                                       0
                                       0
                                       0
                                       0
                                     0.00
b. Deviations
                                      24
                                       2
                                      24
                                    2[[2]]
                                      48
                                      48
                                      2.4
                                      4.8
                                   4,450.27
c. SS&M Report
                                       8
                                       2
                                       8
                                       2
                                      16
                                      16
                                      0.8
                                      1.6
                                   1,483.42
d. LDAR Report
                                      404
                                       2
                                    1[[3]]
                                       4
                                       4
                                       4
                                      0.2
                                      0.4
                                    370.86
e. Emission Averaging report
                                      20
                                       2
                                      20
                                       0
                                       0
                                       0
                                       0
                                       0
                                     0.00
4. Recordkeeping Requirements
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
a. Read rule and instructions
                                 Included in 3e
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
b. Plan Activities 
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
c. Implement Activities 
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
d. Develop Record System
                                      40
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
e. Develop SS&M Plan
                                      100
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
f. Develop QA/QC Plan for CMS
                                      40
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
g. Time to train personnel
                                      40
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
h. Time to retrain/refresh personnel
                                      16
                                       1
                                      16
                                       1
                                      16
                                      16
                                      0.8
                                      1.6
                                   1,483.42
i. Time to enter information
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
i. Records of SS&M
                                      1.5
                                      52
                                      1.5
                                      52
                                      78
                                      78
                                      3.9
                                      7.8
                                   7,231.69
Table C.7 Model Chemical Plant  -  40 CFR Part 63, Subpart FFFF Supporting Statement Analysis (Cont.) [[1]]
                                 Burden item 
                                      (A)
                                      (B)
                                      (D)
                                      (E)
                                      (F)
                                      (G)
                                      (H)
                                      (I)
                                      (J)

        Person-hours per occurrence for SFI (from supporting statement)
    No. of occurrences per respondent per year (from supporting statement)
        Person-hours per occurrence applicable to Model Chemical Plant 
           No. of occurrences for the Model Chemical Plant per year
              Person-hours for the Model Chemical Plant per year
                            Technical Hours
(hr/yr)
                           Managerial Hours
(hr/yr)
                            Clerical Hours
(hr/yr)
  Total Cost ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr

                                       
                                       
                                       
                                       
                                       
                                     (G=F)
                                  (H=G*0.05)
                                  (I=G*0.10)
                                       
ii. Records of CMS data
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
a. Record of Continuously Monitored Parameters
                                       1
                                      365
                                       1
                                      12
                                      12
                                      12
                                      0.6
                                      1.2
                                   1,112.57
b. Compile Data
                                      24
                                       2
                                      24
                                       2
                                      48
                                      48
                                      2.4
                                      4.8
                                   4,450.27
c. Enter/verify Information for Semiannual report
                                      16
                                       2
                                      16
                                       2
                                      32
                                      32
                                      1.6
                                      3.2
                                   2,966.85
d. LDAR
                                 Included in 3e
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
j. Calibration of CMS
                                      16
                                       1
                                      16
                                       1
                                      16
                                      16
                                      0.8
                                      1.6
                                   1,483.42
TOTAL with Paper Reporting Paper (Sum of Items Under 3.e.xi)
                                     6,305
TOTAL with Electronic Reporting
                                       0
TOTAL Record Keeping (Sum of Items 4.h through 4.j)
                                    18,728
[1] The referenced supporting statement contains several footnotes associated with the original burden estimate.  Please refer to the original supporting statement, included in the rulemaking docket. 
[2] Assumed one deviation per semiannual report at model chemical plant. 
[3] Changed to 1 hour because Method 21 testing is counted in cost impacts and 1 hour per process unit should be adequate time to transmit the data from the analyzer to a computer.
                                       

Table C.8 Model Chemical Plant  -  40 CFR Part 63, Subpart G, H, and I Supporting Statement Analysis [[1][,2][]]
                                 Burden item 
                                      (A)
                                      (B)
                                      (D)
                                      (E)
                                      (F)
                                      (G)
                                      (H)
                                      (I)
                                      (J)

        Person-hours per occurrence for SFI (from supporting statement)
    No. of occurrences per respondent per year (from supporting statement)
        Person-hours per occurrence applicable to Model Chemical Plant 
           No. of occurrences for the Model Chemical Plant per year
              Person-hours for the Model Chemical Plant per year
                            Technical Hours
(hr/yr)
                           Managerial Hours
(hr/yr)
                            Clerical Hours
(hr/yr)
  Total Cost ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr

                                       
                                       
                                       
                                       
                                       
                                     (G=F)
                                  (H=G*0.05)
                                  (I=G*0.10)
                                       
1. Applications
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
2. Surveys and Studies
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
3. Reporting Requirements
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
a. Read rule and instructions
                                       1
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
b. Required Activities
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
i. Initial Performance Test - process vents
                                      480
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
ii. Initial Performance Test - wastewater
                                      160
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
iii. Initial CMS performance evaluation
                                      10
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
iv. Repeat Performance Test
                                      20
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
c. Create Information 
                                Included in 3e
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
d. Gather existing Information 
                                Included in 3e
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
e. Write Reports
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
i. Notification of Construction/Reconstruction
                                       2
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
ii. Notification of Actual Startup
                                       2
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
iii. Initial Notification
                                       2
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
iv. Emissions Averaging Plan
                                      40
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
v. Precompliance Report
                                      40
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
vii. Performance Test Notification
                                       2
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
viii. Notification of Initial CMS performance evaluation
                                       2
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
ix. Notification of Compliance Status
                                       
                                       
                                       
                                       
                                       
                                       0
                                       0
                                       0
                                       0
Table C.8 Model Chemical Plant  -  40 CFR Part 63, Subpart G, H, and I Supporting Statement Analysis (Cont.) [[1][,2][]]
                                 Burden item 
                                      (A)
                                      (B)
                                      (D)
                                      (E)
                                      (F)
                                      (G)
                                      (H)
                                      (I)
                                      (J)

        Person-hours per occurrence for SFI (from supporting statement)
    No. of occurrences per respondent per year (from supporting statement)
        Person-hours per occurrence applicable to Model Chemical Plant 
           No. of occurrences for the Model Chemical Plant per year
              Person-hours for the Model Chemical Plant per year
                            Technical Hours
(hr/yr)
                           Managerial Hours
(hr/yr)
                            Clerical Hours
(hr/yr)
  Total Cost ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr

                                       
                                       
                                       
                                       
                                       
                                     (G=F)
                                  (H=G*0.05)
                                  (I=G*0.10)
                                       
a. With performance test
                                      80
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
b. W/O performance test
                                      120
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
x. Notification of Physical/ Operational Change
                                       8
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
xi. Semiannual Summary Report
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
a. No Deviations
                                       8
                                       2
                                       8
                                       0
                                       0
                                       0
                                       0
                                       0
                                     0.00
b. Deviations
                                      24
                                       2
                                      24
                                    2[[3]]
                                      48
                                      48
                                      2.4
                                      4.8
                                   4,450.27
c. SS&M Report
                                       8
                                       2
                                       8
                                       2
                                      16
                                      16
                                      0.8
                                      1.6
                                   1,483.42
d. LDAR Report
                                      404
                                       2
                                    1[[4]]
                                       4
                                       4
                                       4
                                      0.2
                                      0.4
                                    370.86
e. Emission Averaging report
                                      20
                                       2
                                      20
                                       0
                                       0
                                       0
                                       0
                                       0
                                     0.00
4. Recordkeeping Requirements
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
a. Read rule and instructions
                                 Included in 3e
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
b. Plan Activities 
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
c. Implement Activities 
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
d. Develop Record System
                                      40
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
e. Develop SS&M Plan
                                      100
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
f. Develop QA/QC Plan for CMS
                                      40
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
g. Time to train personnel
                                      40
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
h. Time to retrain/refresh personnel
                                      16
                                       1
                                      16
                                       1
                                      16
                                      16
                                      0.8
                                      1.6
                                   1,483.42
i. Time to enter information
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
i. Records of SS&M
                                      1.5
                                      52
                                      1.5
                                      52
                                      78
                                      78
                                      3.9
                                      7.8
                                   7,231.69
Table C.8 Model Chemical Plant  -  40 CFR Part 63, Subpart G, H, and I Supporting Statement Analysis (Cont.) [[1][,2][]]
                                 Burden item 
                                      (A)
                                      (B)
                                      (D)
                                      (E)
                                      (F)
                                      (G)
                                      (H)
                                      (I)
                                      (J)

        Person-hours per occurrence for SFI (from supporting statement)
    No. of occurrences per respondent per year (from supporting statement)
        Person-hours per occurrence applicable to Model Chemical Plant 
           No. of occurrences for the Model Chemical Plant per year
              Person-hours for the Model Chemical Plant per year
                            Technical Hours
(hr/yr)
                           Managerial Hours
(hr/yr)
                            Clerical Hours
(hr/yr)
  Total Cost ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr

                                       
                                       
                                       
                                       
                                       
                                     (G=F)
                                  (H=G*0.05)
                                  (I=G*0.10)
                                       
ii. Records of CMS data
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
a. Record of Continuously Monitored Parameters
                                       1
                                      365
                                       1
                                      10
                                      10
                                      10
                                      0.5
                                       1
                                    927.14
b. Compile Data
                                      24
                                       2
                                      24
                                       2
                                      48
                                      48
                                      2.4
                                      4.8
                                   4,450.27
c. Enter/verify Information for Semiannual report
                                      16
                                       2
                                      16
                                       2
                                      32
                                      32
                                      1.6
                                      3.2
                                   2,966.85
d. LDAR
                                Included in 3e
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
j. Calibration of CMS
                                      16
                                       1
                                      16
                                       1
                                      16
                                      16
                                      0.8
                                      1.6
                                   1,483.42
TOTAL with Paper Reporting Paper (Sum of Items Under 3.e.xi)
                                     6,305
TOTAL with Electronic Reporting
                                       0
TOTAL Record Keeping (Sum of Items 4.h through 4.j)
                                    18,543
[1] The referenced supporting statement contains several footnotes associated with the original burden estimate.  Please refer to the original supporting statement, included in the rulemaking docket. 
[2] Original Subpart G/H/I (HON) supporting statement was unavailable for the analysis; therefore, Subpart FFFF was used to estimate the burden under Subpart G/H/I (HON). 
[3] Assumed one deviation per semiannual report at model chemical plant. 
[4] Changed to 1 hour because Method 21 testing is counted in cost impacts and 1 hour per process unit should be adequate time to transmit the data from the analyzer to a computer.
                                       
                                  Appendix D:
                                       
                      Electronic Reporting Cost Analysis
Table D.1 Initial Start Up Cost for Electronic Reporting for the Model Refinery
                                       
                                Emission Source
                                      (A)
                                      (B)
                                      (C)
                                      (D)
                                      (E)
                                      (F)
                                      (G)
                                      (H)
  TOTAL COST ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr
                                       
                       Count of Occurrences Per Facility
                       Count of Applicable Data Elements
                 Count of Rules Applicable to Emission Source
                         Count of Data Entry Records

                  Hours Required to Enter Data Elements[[1]]

                                Technical Hours
                               Managerial Hours

                                Clerical Hours

                                       
                                       
                                       
                                       
                                       
                                   D=Ax(B+C)
                                    E=D/25
                                       
                                  (G=F*0.05)
                                  (H=F*0.10)
                                       
Transfer Operations[[2]]
                                       2
                                      10
                                       4
                                      28
                                     1.12
                                     1.12
                                     0.06
                                     0.11
                                      104
Equipment Leaks[[3]]
                                      16
                                      19
                                       3
                                      352
                                     14.1
                                     14.1
                                     0.70
                                     1.41
                                     1,305
Process Vents[[4]]
                                       7
                                      12
                                       2
                                      98
                                     3.92
                                     3.92
                                     0.20
                                     0.39
                                      363
Storage Vessels[[5]]
                                      48
                                      12
                                       5
                                      816
                                     32.6
                                     32.6
                                     1.63
                                     3.26
                                     3,026
Generic Data Elements[[6]]
                                      16
                                       9
                                       0
                                      144
                                     5.76
                                     5.76
                                     0.29
                                     0.58
                                      534
                                                                          Total
                                     5,333
[1] Assumed 25 data element entries per hour.
[2] 2 transfer operations at model refinery (marine dock and loading terminal). Assumed 10 data elements - control type, identification number, material loaded, capacity, annual amount of material loaded, and 5 other miscellaneous data elements. Assumed 4 applicable rules listed in Table [Insert Name of Rule Applicability Table 1]. 
[3] 16 process vents are subject to equipment leak standards at the model refinery. Assumed 19 data elements - Count of pumps, compressors, agitators, pressure relief devices, sampling connection systems, open-ended valves or lines, valves, connectors, instrumentation systems, and control devices; classification of equipment; location of equipment; control type for equipment; regulated material status; HAP/VOC; and 5 other miscellaneous data elements. Assumed 3 applicable rules listed in Table [insert name of Rule Applicability Table 1]. 
[4] 7 process vents are subject to process vent standards at the model refinery. Assumed 12 data elements - control type, identification number, flow, concentration, TRE, description, regulated material status, and 5 other miscellaneous data elements. Assumed 2 applicable rules listed in Table [insert name of Rule Applicability Table 1]. 
[5] 48 tanks are subject to storage vessel requirements at the model refinery. Assumed 12 data elements - size, orientation, materials being stored, installation date, control type, capacity, vapor pressure, and 5 other miscellaneous elements. Assumed 5 applicable rules listed in Table [insert name of Rule Applicability Table 1].
[6] 16 process units require generic data elements at the model refinery. Assumed 9 data elements - facility contact name, address, phone number, facility type (process), and 5 other miscellaneous data elements. 
 
Table D.2 Initial Start Up Cost for Electronic Reporting for the Model Chemical Plant
                                       
                                Emission Source
                                      (A)
                                      (B)
                                      (C)
                                      (D)
                                      (E)
                                      (F)
                                      (G)
                                      (H)
  TOTAL COST ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr
                                       
                       Count of Occurrences Per Facility
                       Count of Applicable Data Elements
                 Count of Rules Applicable to Emission Source
                         Count of Data Entry Records

                  Hours Required to Enter Data Elements[[1]]

                                Technical Hours
                               Managerial Hours

                                Clerical Hours

                                       
                                       
                                       
                                       
                                       
                                   D=Ax(B+C)
                                    E=D/25
                                       
                                  (G=F*0.05)
                                  (H=F*0.10)
                                       
Transfer Operations[[2]]
                                       7
                                      10
                                       2
                                      84
                                     3.36
                                     3.36
                                     0.17
                                     0.34
                                      312
Equipment Leaks[[3]]
                                       3
                                      19
                                       4
                                      69
                                      2.8
                                      2.8
                                     0.14
                                     0.28
                                      256
Process Vents[[4]]
                                      14
                                      12
                                       4
                                      224
                                     8.96
                                     8.96
                                     0.45
                                     0.90
                                      831
Storage Vessels[[5]]
                                      20
                                      12
                                       4
                                      320
                                     12.8
                                     12.8
                                     0.64
                                     1.28
                                     1,187
Generic Data Elements[[6]]
                                       3
                                       9
                                       0
                                      27
                                     1.08
                                     1.08
                                     0.05
                                     0.11
                                      100
                                                                          Total
                                     2,685
[1] Assumed 25 data element entries per hour.
[2] 7 transfer operations at model chemical plant. Assumed 10 data elements - control type, identification number, material loaded, capacity, annual amount of material loaded, and 5 other miscellaneous data elements. Assumed 4 applicable rules listed in Table [Insert Name of Rule Applicability Table 1]. 
[3] 3 process vents are subject to equipment leak standards  at model chemical plant.  Assumed 19 data elements - Count of pumps, compressors, agitators, pressure relief devices, sampling connection systems, open-ended valves or lines, valves, connectors, instrumentation systems, and control devices; classification of equipment; location of equipment; control type for equipment; regulated material status; HAP/VOC; and 5 other miscellaneous data elements. Assumed 3 applicable rules listed in Table [insert name of Rule Applicability Table 1]. 
[4] 14 process vents are subject to process vent standards  at model chemical plant. Assumed 12 data elements - control type, identification number, flow, concentration, TRE, description, regulated material status, and 5 other miscellaneous data elements. Assumed 2 applicable rules listed in Table [insert name of Rule Applicability Table 1]. 
[5] 20 tanks are subject to storage vessel requirements at model chemical plant. Assumed 12 data elements - size, orientation, materials being stored, installation date, control type, capacity, vapor pressure, and 5 other miscellaneous elements. Assumed 5 applicable rules listed in Table [insert name of Rule Applicability Table 1].
[6] 3 process units require generic data elements at model chemical plant. Assumed 9 data elements - facility contact name, address, phone number, facility type (process), and 5 other miscellaneous data elements. 
                                       

     Table D.3 Annual Cost for Electronic Reporting for the Model Refinery
                                 Data Element
                                      (A)
                                      (B)
                                      (F)
                                      (G)
                                      (H)
 TOTAL COST ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr 
                                       
                     Data Elements to be Entered Per Year
                          Total Hours per Year[[1]]

                                Technical Hours
                               Managerial Hours

                                Clerical Hours

                                       
                                       
                                       
                                    B=A/25
                                       
                                  (G=F*0.05)
                                  (H=F*0.10)
                                       
Information Required in the Annual Report
                                       
                                       
                                       
                                       
                                       
                                       
Subpart I[[2]]
                                       
                                       
                                       
                                       
                                       
                                       
Inspection records
                                       
                                       
                                       
                                       
                                       
                                       
Defect
                                       5
                                      0.2
                                      0.2
                                     0.01
                                     0.02
                                     18.54
Leak
                                       5
                                      0.2
                                      0.2
                                     0.01
                                     0.02
                                     18.54
Failure
                                       5
                                      0.2
                                      0.2
                                     0.01
                                     0.02
                                     18.54
   Documentation of Emptying for:
                                       
                                       
                                       
                                       
                                       
                                       
Defect
                                       5
                                      0.2
                                      0.2
                                     0.01
                                     0.02
                                     18.54
Leak
                                       5
                                      0.2
                                      0.2
                                     0.01
                                     0.02
                                     18.54
Failure
                                       5
                                      0.2
                                      0.2
                                     0.01
                                     0.02
                                     18.54
   Documentation of Repair for:
                                       
                                       
                                       
                                       
                                       
                                       
Defect
                                       5
                                      0.2
                                      0.2
                                     0.01
                                     0.02
                                     18.54
Leak
                                       5
                                      0.2
                                      0.2
                                     0.01
                                     0.02
                                     18.54
Failure
                                       5
                                      0.2
                                      0.2
                                     0.01
                                     0.02
                                     18.54
   Estimate of Emissions from Floating Roof Landings
                                       5
                                      0.2
                                      0.2
                                     0.01
                                     0.02
                                     18.54
   Estimate of Emission from Overfilling
                                       5
                                      0.2
                                      0.2
                                     0.01
                                     0.02
                                     18.54
   Estimate of Emissions from Pressure Vessel Defects
                                       5
                                      0.2
                                      0.2
                                     0.01
                                     0.02
                                     18.54
Subpart I, Annual Subtotal
                                      60
                                      2.4
                                      2.4
                                     0.12
                                     0.24
                                    222.51
Subpart J[[3]]
                                       
                                       
                                       
                                       
                                       
                                       
Process Unit Identification
                                      16
                                     0.64
                                     0.64
                                     0.032
                                     0.064
                                     59.34
   Count of Leaking Equipment
                                       
                                       
                                       
                                       
                                       
                                       
Valves
                                      16
                                     0.64
                                     0.64
                                     0.032
                                     0.064
                                     59.34

 Table D.3 Annual Cost for Electronic Reporting for the Model Refinery (Cont.)
                                 Data Element
                                      (A)
                                      (B)
                                      (F)
                                      (G)
                                      (H)
 TOTAL COST ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr 
                                       
                     Data Elements to be Entered Per Year
                          Total Hours per Year[[1]]

                                Technical Hours
                               Managerial Hours

                                Clerical Hours

                                       
                                       
                                       
                                    B=A/25
                                       
                                  (G=F*0.05)
                                  (H=F*0.10)
                                       
Pumps
                                      16
                                     0.64
                                     0.64
                                     0.032
                                     0.064
                                     59.34
Connectors
                                      16
                                     0.64
                                     0.64
                                     0.032
                                     0.064
                                     59.34
Agitators
                                      16
                                     0.64
                                     0.64
                                     0.032
                                     0.064
                                     59.34
Compressors
                                      16
                                     0.64
                                     0.64
                                     0.032
                                     0.064
                                     59.34
   Total Count of Valves Monitored
                                      16
                                     0.64
                                     0.64
                                     0.032
                                     0.064
                                     59.34
   Percent Leaking
                                      16
                                     0.64
                                     0.64
                                     0.032
                                     0.064
                                     59.34
   Total Count of Connectors Monitored
                                      16
                                     0.64
                                     0.64
                                     0.032
                                     0.064
                                     59.34
   Percent Leaking 
                                      16
                                     0.64
                                     0.64
                                     0.032
                                     0.064
                                     59.34
   Count of Equipment not Repaired
                                       
                                       
                                       
                                       
                                       
                                       
Valves
                                      16
                                     0.64
                                     0.64
                                     0.032
                                     0.064
                                     59.34
Pumps
                                      16
                                     0.64
                                     0.64
                                     0.032
                                     0.064
                                     59.34
Connectors
                                      16
                                     0.64
                                     0.64
                                     0.032
                                     0.064
                                     59.34
Agitators
                                      16
                                     0.64
                                     0.64
                                     0.032
                                     0.064
                                     59.34
Compressors
                                      16
                                     0.64
                                     0.64
                                     0.032
                                     0.064
                                     59.34
Non-repairable/Inaccessible
                                      16
                                     0.64
                                     0.64
                                     0.032
                                     0.064
                                     59.34
Delay of Repair Report
                                      16
                                     0.64
                                     0.64
                                     0.032
                                     0.064
                                     59.34
   Results of M21 Test Post Release Test for G/V PRD
                                      16
                                     0.64
                                     0.64
                                     0.032
                                     0.064
                                     59.34
   Results of M21 Test for Compressors
                                      16
                                     0.64
                                     0.64
                                     0.032
                                     0.064
                                     59.34
   Results of M21 Test for OEL
                                      16
                                     0.64
                                     0.64
                                     0.032
                                     0.064
                                     59.34
Process vent Requirements 
                                      25
                                       1
                                       1
                                     0.05
                                      0.1
                                     92.71
Subpart J, Annual Subtotal
                                      345
                                     13.8
                                     13.8
                                     0.69
                                     1.38
                                   1,279.45
Subpart M (Annual)
                    There are no annual Subpart M reports.
Information Required in the Semiannual Report
                                       
                                       
                                       
                                       
                                       
                                       
 Table D.3 Annual Cost for Electronic Reporting for the Model Refinery (Cont.)
                                 Data Element
                                      (A)
                                      (B)
                                      (F)
                                      (G)
                                      (H)
 TOTAL COST ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr 
                                       
                     Data Elements to be Entered Per Year
                          Total Hours per Year[[1]]

                                Technical Hours
                               Managerial Hours

                                Clerical Hours

                                       
                                       
                                       
                                    B=A/25
                                       
                                  (G=F*0.05)
                                  (H=F*0.10)
                                       
Subpart I[[4]]
                                       
                                       
                                       
                                       
                                       
                                       
Storage Vessel ID
                                      10
                                      0.4
                                      0.4
                                     0.02
                                     0.04
                                     37.09
Date of Empty/Repair
                                      10
                                      0.4
                                      0.4
                                     0.02
                                     0.04
                                     37.09
   Start Date Floating Roof Landing Does Not Meet 65.315(b)(1)
                                      10
                                      0.4
                                      0.4
                                     0.02
                                     0.04
                                     37.09
   End Date Floating Roof Landing Does Not Meet 65.315(b)(1)
                                      10
                                      0.4
                                      0.4
                                     0.02
                                     0.04
                                     37.09
   Inspection record for pressure vessels
                                      10
                                      0.4
                                      0.4
                                     0.02
                                     0.04
                                     37.09
Subpart I, Semiannual Subtotal
                                      50
                                       2
                                       2
                                      0.1
                                      0.2
                                    185.43
Subpart J
                                       
                                       
                                       
                                       
                                       
                                       
PRD Release[[5]]
                                       
                                       
                                       
                                       
                                       
                                       
PRD ID
                                      160
                                      6.4
                                      6.4
                                     0.32
                                     0.64
                                    593.37
      Duration of PRD Release
                                      160
                                      6.4
                                      6.4
                                     0.32
                                     0.64
                                    593.37
      Emissions from PRD Release
                                      160
                                      6.4
                                      6.4
                                     0.32
                                     0.64
                                    593.37
Compressor Leak[[6]]
                                       
                                       
                                       
                                       
                                       
                                       
Compressor ID
                                      32
                                     1.28
                                     1.28
                                     0.064
                                     0.128
                                    118.67
      Number of days between Instrument Reading
                                      32
                                     1.28
                                     1.28
                                     0.064
                                     0.128
                                    118.67
OEL Leak (Cap and Plug)[[6]]
                                       
                                       
                                       
                                       
                                       
                                       
OEL ID
                                      32
                                     1.28
                                     1.28
                                     0.064
                                     0.128
                                    118.67
      Number of days between Instrument Reading
                                      32
                                     1.28
                                     1.28
                                     0.064
                                     0.128
                                    118.67
   OEL Release from Emergency Shutdown[[6]]
                                       
                                       
                                       
                                       
                                       
                                       
OEL ID
                                      32
                                     1.28
                                     1.28
                                     0.064
                                     0.128
                                    118.67
Number of Releases
                                      32
                                     1.28
                                     1.28
                                     0.064
                                     0.128
                                    118.67
 Table D.3 Annual Cost for Electronic Reporting for the Model Refinery (Cont.)
                                 Data Element
                                      (A)
                                      (B)
                                      (F)
                                      (G)
                                      (H)
 TOTAL COST ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr 
                                       
                     Data Elements to be Entered Per Year
                          Total Hours per Year[[1]]

                                Technical Hours
                               Managerial Hours

                                Clerical Hours

                                       
                                       
                                       
                                    B=A/25
                                       
                                  (G=F*0.05)
                                  (H=F*0.10)
                                       
   Low Barrier Pressure Fluid[[6]]
                                       
                                       
                                       
                                       
                                       
                                       
Equipment ID
                                      32
                                     1.28
                                     1.28
                                     0.064
                                     0.128
                                    118.67
Number of Occurrences
                                      32
                                     1.28
                                     1.28
                                     0.064
                                     0.128
                                    118.67
Subpart J, Semiannual Subtotal
                                      736
                                     29.4
                                     29.44
                                     1.472
                                     2.944
                                   2,729.50
Subpart M
                                       
                                       
                                       
                                       
                                       
                                       
Process Vents[[7]]
                                       
                                       
                                       
                                       
                                       
                                       
Process Unit ID
                                      140
                                      5.6
                                      5.6
                                     0.28
                                     0.56
                                    519.20
   Start/End Date of Reporting Period
                                      140
                                      5.6
                                      5.6
                                     0.28
                                     0.56
                                    519.20
   Start/End Date of Exceedence (Above Emission Limit/Parameter)
                                      140
                                      5.6
                                      5.6
                                     0.28
                                     0.56
                                    519.20
   Average Parameter or Emission During Exceedence
                                      140
                                      5.6
                                      5.6
                                     0.28
                                     0.56
                                    519.20
Subpart M, Semiannual Subtotal
                                      560
                                     22.4
                                     22.4
                                     1.12
                                     2.24
                                   2,076.79
 
                                       
                                       
                                       
                                       
                                       
                                       
Log In/Out Time[[8]]
                                       
                                       
                                       
                                       
                                       
                                       
Annual Report
                                       
                                       
                                       
                                       
                                       
                                       
Storage Vessels
                                       
                                      1.5
                                      1.5
                                     0.075
                                     0.15
                                    139.07
Equipment Leaks
                                       
                                      1.5
                                      1.5
                                     0.075
                                     0.15
                                    139.07
Process Vents
                                       
                                      1.5
                                      1.5
                                     0.075
                                     0.15
                                    139.07
Login/Out Subtotal (due to annual report)
                                       
                                      4.5
                                      4.5
                                     0.225
                                     0.45
                                    417.21
Semi Annual Report
                                       
                                       
                                       
                                       
                                       
                                       
Storage Vessels
                                       
                                       3
                                       3
                                     0.15
                                      0.3
                                    278.14
Equipment Leaks
                                       
                                       3
                                       3
                                     0.15
                                      0.3
                                    278.14
Process Vents
                                       
                                       3
                                       3
                                     0.15
                                      0.3
                                    278.14

 Table D.3 Annual Cost for Electronic Reporting for the Model Refinery (Cont.)
                                 Data Element
                                      (A)
                                      (B)
                                      (F)
                                      (G)
                                      (H)
 TOTAL COST ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr 
                                       
                     Data Elements to be Entered Per Year
                          Total Hours per Year[[1]]

                                Technical Hours
                               Managerial Hours

                                Clerical Hours

                                       
                                       
                                       
                                    B=A/25
                                       
                                  (G=F*0.05)
                                  (H=F*0.10)
                                       
Login/Out Subtotal (due to semiannual report)
                                       
                                       9
                                       9
                                     0.45
                                      0.9
                                    834.43
Total Annual Hourly Reporting Requirement
                                       
                                     83.5
                                     83.5
                                      4.2
                                      8.4
                                                            7,745.33 
[1] Assumed 25 data elements entered per hour.






[2] Assumed 10% of 48 Tanks (approximately 5).
[3] Assumed 1 instance for every process unit (16 process units).
[4] Assumed 10% of 48 Tanks (approximately 5) with data elements entered twice a year for semiannual reporting. 
[5] Assumed 5 releases per process units (16 process units) with data elements entered twice a year for semiannual reporting.
[6] Assumed 1 occurrence per process unit (16 process units) with data elements entered twice a year for semiannual reporting.
[7] Assumed 10 instances for every process vent (7 process vents) with data elements entered twice a year for semiannual reporting.
[8] Assumed a general 1.5 hour period to log in and out of system for each report to account for administrative issues such as account and password.
                                       

  Table D.4 Annual Cost for Electronic Reporting for the Model Chemical Plant
                                 Data Element
                   (A) Data Elements to be Entered Per Year
                     (B) Total Hours per Year[[1]]
B=A/25
                              (F) Technical Hours
                        (G) Managerial Hours
(G=F*0.05)
                         (H) Clerical Hours
(H=F*0.10)
  TOTAL COST ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr 
Information Required in the Annual Report
                                       
                                       
                                       
                                       
                                       
                                       
Subpart I[[2]]
 
 
 
 
 
 
Inspection records
 
 
 
 
 
 
Defect
                                       2
                                     0.08
                                     0.08
                                     0.004
                                     0.008
                                                                  7.42 
Leak
                                       2
                                     0.08
                                     0.08
                                     0.004
                                     0.008
                                                                  7.42 
Failure
                                       2
                                     0.08
                                     0.08
                                     0.004
                                     0.008
                                                                  7.42 
Documentation of Emptying for:
                                       
                                       
                                       
                                       
                                       
                                       
Defect
                                       2
                                     0.08
                                     0.08
                                     0.004
                                     0.008
                                                                  7.42 
Leak
                                       2
                                     0.08
                                     0.08
                                     0.004
                                     0.008
                                                                  7.42 
Failure
                                       2
                                     0.08
                                     0.08
                                     0.004
                                     0.008
                                                                  7.42 
Documentation of Repair for:
                                       
                                       
                                       
                                       
                                       
                                       
Defect
                                       2
                                     0.08
                                     0.08
                                     0.004
                                     0.008
                                                                  7.42 
Leak
                                       2
                                     0.08
                                     0.08
                                     0.004
                                     0.008
                                                                  7.42 
Failure
                                       2
                                     0.08
                                     0.08
                                     0.004
                                     0.008
                                                                  7.42 
Estimate of Emissions from Floating Roof Landings
                                       2
                                     0.08
                                     0.08
                                     0.004
                                     0.008
                                                                  7.42 
Estimate of Emission from Overfilling
                                       2
                                     0.08
                                     0.08
                                     0.004
                                     0.008
                                                                  7.42 
Estimate of Emissions from Pressure Vessel Defects
                                       2
                                     0.08
                                     0.08
                                     0.004
                                     0.008
                                                                  7.42 
                                                                          Total
                                      24
                                     0.96
                                     0.96
                                     0.048
                                     0.096
                                                                89.01 
Subpart J[[3]]
                                       
                                       
                                       
                                       
                                       
                                       
Process Unit Identification
                                       3
                                     0.12
                                     0.12
                                     0.006
                                     0.012
                                                                 11.13 
Count of Leaking Equipment
                                       3
                                       
                                       
                                       
                                       
                                       




Table D.4 Annual Cost for Electronic Reporting for the Model Chemical Plant (Cont.)
                                 Data Element
                   (A) Data Elements to be Entered Per Year
                     (B) Total Hours per Year[[1]]
B=A/25
                              (F) Technical Hours
                        (G) Managerial Hours
(G=F*0.05)
                         (H) Clerical Hours
(H=F*0.10)
  TOTAL COST ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr 
Valves
                                       3
                                     0.12
                                     0.12
                                     0.006
                                     0.012
                                                                 11.13 
Pumps
                                       3
                                     0.12
                                     0.12
                                     0.006
                                     0.012
                                                                 11.13 
Connectors
                                       3
                                     0.12
                                     0.12
                                     0.006
                                     0.012
                                                                 11.13 
Agitators
                                       3
                                     0.12
                                     0.12
                                     0.006
                                     0.012
                                                                 11.13 
Compressors
                                       3
                                     0.12
                                     0.12
                                     0.006
                                     0.012
                                                                 11.13 
Total Count of Valves Monitored
                                       3
                                     0.12
                                     0.12
                                     0.006
                                     0.012
                                                                 11.13 
Percent Leaking
                                       3
                                     0.12
                                     0.12
                                     0.006
                                     0.012
                                                                 11.13 
Total Count of Connectors Monitored
                                       3
                                     0.12
                                     0.12
                                     0.006
                                     0.012
                                                                 11.13 
Percent Leaking 
                                       3
                                     0.12
                                     0.12
                                     0.006
                                     0.012
                                                                 11.13 
Count of Equipment not Repaired
                                       
                                       
                                       
                                       
                                       
                                       
Valves
                                       3
                                     0.12
                                     0.12
                                     0.006
                                     0.012
                                                                 11.13 
Pumps
                                       3
                                     0.12
                                     0.12
                                     0.006
                                     0.012
                                                                 11.13 
Connectors
                                       3
                                     0.12
                                     0.12
                                     0.006
                                     0.012
                                                                 11.13 
Agitators
                                       3
                                     0.12
                                     0.12
                                     0.006
                                     0.012
                                                                 11.13 
Compressors
                                       3
                                     0.12
                                     0.12
                                     0.006
                                     0.012
                                                                 11.13 
Non-repairable/Inaccessible
                                       3
                                     0.12
                                     0.12
                                     0.006
                                     0.012
                                                                 11.13 
Delay of Repair Report
                                       3
                                     0.12
                                     0.12
                                     0.006
                                     0.012
                                                                 11.13 
Results of M21 Test Post Release Test for G/V PRD
                                       3
                                     0.12
                                     0.12
                                     0.006
                                     0.012
                                                                 11.13 
Results of M21 Test for Compressors
                                       3
                                     0.12
                                     0.12
                                     0.006
                                     0.012
                                                                 11.13 
Results of M21 Test for OEL
                                       3
                                     0.12
                                     0.12
                                     0.006
                                     0.012
                                                                 11.13 


Table D.4 Annual Cost for Electronic Reporting for the Model Chemical Plant (Cont.)
                                 Data Element
                   (A) Data Elements to be Entered Per Year
                     (B) Total Hours per Year[[1]]
B=A/25
                              (F) Technical Hours
                        (G) Managerial Hours
(G=F*0.05)
                         (H) Clerical Hours
(H=F*0.10)
  TOTAL COST ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr 
Process vent Requirements 
                                      14
                                     0.56
                                     0.56
                                     0.028
                                     0.056
                                                                 51.92 
                                                                          Total
                                      77
                                     2.96
                                     2.96
                                     0.148
                                     0.296
                                                               274.43 
Subpart M
                    There are no annual Subpart M reports.
Information Required in the Semiannual Report
                                       
                                       
                                       
                                       
                                       
                                       
Subpart I[[4]]
                                       
                                       
                                       
                                       
                                       
                                       
Storage Vessel ID
                                       4
                                     0.16
                                     0.16
                                     0.008
                                     0.016
                                                                 14.83 
Date of Empty/Repair
                                       4
                                     0.16
                                     0.16
                                     0.008
                                     0.016
                                                                 14.83 
Start Date Floating Roof Landing Does Not Meet 65.315(b)(1)
                                       4
                                     0.16
                                     0.16
                                     0.008
                                     0.016
                                                                 14.83 
End Date Floating Roof Landing Does Not Meet 65.315(b)(1)
                                       4
                                     0.16
                                     0.16
                                     0.008
                                     0.016
                                                                 14.83 
Inspection record for pressure vessels
                                       4
                                     0.16
                                     0.16
                                     0.008
                                     0.016
                                                                 14.83 
                                                                          Total
                                      20
                                      0.8
                                      0.8
                                     0.04
                                     0.08
                                                                74.17 
Subpart J
                                       
                                       
                                       
                                       
                                       
                                       
PRD Release[[5]]
                                       
                                       
                                       
                                       
                                       
                                       
PRD ID
                                      30
                                      1.2
                                      1.2
                                     0.06
                                     0.12
                                                                111.26 
Duration of PRD Release
                                      30
                                      1.2
                                      1.2
                                     0.06
                                     0.12
                                                                111.26 
Emissions from PRD Release
                                      30
                                      1.2
                                      1.2
                                     0.06
                                     0.12
                                                                111.26 
Compressor Leak[[6]]
                                       
                                       
                                       
                                       
                                       
                                       
Compressor ID
                                       6
                                     0.24
                                     0.24
                                     0.012
                                     0.024
                                                                 22.25 
Number of days between Instrument Reading
                                       6
                                     0.24
                                     0.24
                                     0.012
                                     0.024
                                                                 22.25 
OEL Leak (Cap and Plug)[[6]]
                                       
                                       
                                       
                                       
                                       
                                       
OEL ID
                                       6
                                     0.24
                                     0.24
                                     0.012
                                     0.024
                                                                 22.25 


Table D.4 Annual Cost for Electronic Reporting for the Model Chemical Plant (Cont.)
                                 Data Element
                   (A) Data Elements to be Entered Per Year
                     (B) Total Hours per Year[[1]]
B=A/25
                              (F) Technical Hours
                        (G) Managerial Hours
(G=F*0.05)
                         (H) Clerical Hours
(H=F*0.10)
  TOTAL COST ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr 
Number of days between Instrument Reading
                                       6
                                     0.24
                                     0.24
                                     0.012
                                     0.024
                                                                 22.25 
OEL Release from Emergency Shutdown[[6]]
                                       
                                       
                                       
                                       
                                       
                                       
OEL ID
                                       6
                                     0.24
                                     0.24
                                     0.012
                                     0.024
                                                                 22.25 
Number of Releases
                                       6
                                     0.24
                                     0.24
                                     0.012
                                     0.024
                                                                 22.25 
Low Barrier Pressure Fluid[[6]]
                                       
                                       
                                       
                                       
                                       
                                       
Equipment ID
                                       6
                                     0.24
                                     0.24
                                     0.012
                                     0.024
                                                                 22.25 
Number of Occurrences
                                       6
                                     0.24
                                     0.24
                                     0.012
                                     0.024
                                                                 22.25 
                                                                          Total
                                      138
                                      5.5
                                     5.52
                                     0.276
                                     0.552
                                                               511.78 
Subpart M
                                       
                                       
                                       
                                       
                                       
                                       
Process Vents[[7]]
                                       
                                       
                                       
                                       
                                       
                                       
Process Unit ID
                                      280
                                     11.2
                                     11.2
                                     0.56
                                     1.12
                                                             1,038.40 
Start/End Date of Reporting Period
                                      280
                                     11.2
                                     11.2
                                     0.56
                                     1.12
                                                             1,038.40 
Start/End Date of Exceedence (Above Emission Limit/Parameter)
                                      280
                                     11.2
                                     11.2
                                     0.56
                                     1.12
                                                             1,038.40 
Average Parameter or Emission During Exceedence
                                      280
                                     11.2
                                     11.2
                                     0.56
                                     1.12
                                                             1,038.40 
                                                                          Total
                                     1120
                                     44.8
                                     44.8
                                     2.24
                                     4.48
                                                                        4153.59
Log In/Out Time[[8]]
                                       
                                       
                                       
                                       
                                       
                                       
Annual Report
                                       
                                       
                                       
                                       
                                       
                                       
Storage Vessels
                                       
                                      1.5
                                      1.5
                                     0.075
                                     0.15
                                                                         139.07
Equipment Leaks
                                       
                                      1.5
                                      1.5
                                     0.075
                                     0.15
                                                                         139.07
Process Vents
                                       
                                      1.5
                                      1.5
                                     0.075
                                     0.15
                                                                         139.07


Table D.4 Annual Cost for Electronic Reporting for the Model Chemical Plant (Cont.)
                                 Data Element
                   (A) Data Elements to be Entered Per Year
                     (B) Total Hours per Year[[1]]
B=A/25
                              (F) Technical Hours
                        (G) Managerial Hours
(G=F*0.05)
                         (H) Clerical Hours
(H=F*0.10)
  TOTAL COST ($)
Technical $83.01/hr
Managerial $121.38/hr
Clerical $36.35/hr 
                                      Login/Out Subtotal (due to annual report)
                                       
                                      4.5
                                      4.5
                                     0.225
                                     0.45
                                                                         417.21
Semi Annual Report
                                       
                                       
                                       
                                       
                                       
                                       
Storage Vessels
                                       
                                       3
                                       3
                                     0.15
                                      0.3
                                                                         278.14
Equipment Leaks
                                       
                                       3
                                       3
                                     0.15
                                      0.3
                                                                         278.14
Process Vents
                                       
                                       3
                                       3
                                     0.15
                                      0.3
                                                                         278.14
                 Login/Out Subtotal (due to semiannual report)
                                       
                                       9
                                       9
                                     0.45
                                      0.9
                                                               834.43 
                                      Total Annual Hourly Reporting Requirement
                                       
                                     68.5
                                     68.5
                                      3.4
                                      6.9
                                                            6,354.62 
[1] Assumed 25 data elements entered per hour.
[2] Assumed 10% of 20 Tanks.






[3] Assumed 1 instance for every process unit (3 process units).





[4] Assumed 10% of 20 Tanks with data elements entered twice a year for semiannual reporting. 




[5] Assumed 5 releases per process unit (3 process units) with data elements entered twice a year for semiannual reporting



[6] Assumed 1 occurrence per process unit (3 process units) with data elements entered twice a year for semiannual reporting


[7] Assumed 10 instances for every process vent (14 process vents) with data elements entered twice a year for semiannual reporting

[8] Assumed a general 1.5 hour period to log in and out of system for each report to account for administrative issues such as account and password. 


                                       
