1
SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
NSPS
SUBPART
Ka
STANDARDS
OF
PERFORMANCE
FOR
STORAGE
VESSELS
OF
PETROLEUM
LIQUIDS
FOR
WHICH
CONSTRUCTION,
RECONSTRUCTION
OR
MODIFICATION
COMMENCED
AFTER
MAY
18,
1978
AND
PRIOR
TO
JULY
23,
1984
1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
NSPS
Ka­
Standards
Of
Performance
For
Storage
Vessels
For
Petroleum
Liquids
for
Which
Construction,
Reconstruction
or
Modification
Commenced
After
May
18,
1978
and
Prior
to
July
23,
1984.

1(
b)
Short
Characterization/
Abstract
The
New
Source
Performance
Standards
(
NSPS)
for
Subpart
Ka
was
proposed
on
May
18,
1978
and
promulgated
on
April
4,
1980.
These
standards
apply
to
the
following
facilities
in
Subpart
Ka:
Storage
Vessels
of
petroleum
liquids
which
has
a
storage
capacity
greater
than
151,416
(
40,000
gallons),
and
for
which
construction,

reconstruction
or
modification
commenced
after
May
18,
1978
and
prior
to
July
23,

1984.

Owners
or
operators
of
the
affected
facilities
described
must
make
one­
time­
only
notifications
including:
notification
of
any
physical
or
operational
change
to
an
existing
facility
which
may
increase
the
regulated
pollutant
emission
rate,
notification
of
the
initial
performance
test;
including
information
necessary
to
determine
the
conditions
of
2
the
performance
test,
and
performance
test
measurements
and
results.
Owners
or
operators
are
also
required
to
maintain
records
of
the
occurrence
and
duration
of
any
startup,
shutdown,
or
malfunction
in
the
operation
of
an
affected
facility,
or
any
period
during
which
the
monitoring
system
is
inoperative.
Measuring
requirements
specific
to
NSPS
Subpart
Ka
provide
information
on
the
operation
of
the
emissions
control
devices.
These
notifications,
reports
and
records
are
required,
in
general,
of
all
sources
subject
to
NSPS.

Any
owner
or
operator
subject
to
the
provisions
of
this
part
shall
maintain
a
file
of
these
measurements,
and
retain
the
file
for
at
least
two
years.
All
reports
are
sent
to
the
delegated
State
or
local
authority.
In
the
event
that
there
is
no
such
delegated
authority,
the
reports
are
sent
directly
to
the
EPA
Regional
Office.

Prior
to
January
19,
2001,
approximately
174
respondents
were
subject
to
the
NSPS
Subpart
Ka.
After
that
time,
OMB
approved
the
Consolidated
Air
Rule
for
the
SOCMI
Industry.
It
is
estimated
that
10%
of
the
174
respondents
will
take
advantage
of
the
new
Rule.
The
number
of
respondents
expected
to
adhere
to
NSPS
Subpart
Ka
is
157.
No
new
sources
are
expected
to
become
subject
to
NSPS
Subpart
Ka.
If
any
new
sources
become
operational,
they
would
be
subject
to
NSPS
Subpart
Kb,
the
most
recent
volatile
organic
compound
(
VOC)
standard
applicable
to
storage
vessels.
The
annual
cost
of
this
ICR
is
$
2,181,783.

The
number
of
respondents
was
based
upon
an
examination
of
Aerometric
Information
Retrieval
System
(
AIRS).
The
number
of
storage
vessels
will
not
increase
due
to
the
open
and
closed
time
frame
of
the
regulations.
There
is
the
potential
for
a
3
decrease
in
the
number
of
storage
vessels.
If
an
owner/
operator
substantially
modifies
a
storage
vessel,
it
becomes
subject
the
NSPS
Subpart
Kb.
The
owner/
operator
is
highly
unlikely
to
exceed
the
modification
requirements..

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

and
periodic
reports.
Owners
or
operators
are
also
required
to
maintain
records
of
the
occurrence
and
duration
of
any
startup,
shutdown,
or
malfunction
in
the
operation
of
an
affected
facility,
or
any
period
during
which
the
monitoring
system
is
inoperative.

These
notifications,
reports,
and
records
are
essential
in
determining
compliance,
are
required,
in
general,
of
all
sources
subject
to
NSPS.

Any
owner
or
operator
subject
to
the
provisions
of
this
part
shall
maintain
a
file
of
this
information
and
retain
the
file
for
at
least
two
years
following
the
date
of
such
measurements,
maintenance
reports,
and
records.
All
reports
are
sent
to
the
delegated
State
or
Local
authority.
In
the
event
that
there
is
no
such
delegated
authority,
the
reports
are
sent
directly
to
the
EPA
Regional
Office.

For
the
currently
approved
ICR
by
OMB
there
were
no
"
Terms
of
Clearance".

2.
Need
for
and
Use
of
the
Collection
2(
a)
Need/
Authority
for
the
Collection
The
EPA
is
charged
under
Section
111
of
the
Clean
Air
Act,
as
amended,
to
establish
standards
of
performance
for
new
stationary
sources
that
reflect:

.
.
.
application
of
the
best
technological
system
of
continuous
emissions
reduction
which
(
taking
into
consideration
the
cost
of
achieving
such
4
emissions
reduction,
or
any
nonair
quality
health
and
environmental
impact
and
energy
requirements)
the
Administrator
determines
has
been
adequately
demonstrated
[
Section
111(
a)(
l)].

The
Agency
refers
to
this
charge
as
selecting
the
best
demonstrated
technology
(
BDT).
Section
111
also
requires
that
the
Administrator
review
and,
if
appropriate,

revise
such
standards
every
four
years.

In
addition,
Section
114(
a)
states
that
the
Administrator
may
require
any
owner
or
operator
subject
to
any
requirement
of
this
Act
to:

.
.
.
(
A)
establish
and
maintain
such
records;
(
B)
make
such
reports;
(
C)

install,
use
and
maintain
such
monitoring
equipment,
and
use
such
audit
procedures,
or
methods;
(
D)
sample
such
emissions
(
in
accordance
with
such
procedures
or
methods,
at
such
locations,
at
such
intervals,
during
such
periods,
and
in
such
a
manner
as
the
Administrator
shall
prescribe);

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

(
F)
submit
compliance
certifications
in
accordance
with
section
114(
a)(
3)

and,
(
G)
provide
additional
information
as
the
Administrator
may
reasonably
require.

In
the
Administrator's
judgment,
volatile
organic
compounds
(
VOCs)
emissions
5
from
Storage
Vessels
For
Petroleum
Liquids
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
the
NSPS
was
promulgated
for
this
source
category
at
40
CFR
Part
60
Subpart
Ka.

2(
b)
Practical
Utility/
Users
of
the
Data
The
control
of
volatile
organic
emissions
from
NSPS
Subpart
Ka
requires
not
only
the
installation
of
properly
designed
equipment,
but
also
the
operation
and
maintenance
of
that
equipment.
For
the
most
part,
volatile
organic
emissions
are
the
result
of
operation
of
petroleum
storage
vessels
at
petroleum
refineries.
These
standards
rely
on
the
reduction
of
volatile
organic
emissions
by
either
internal
or
external
floating
roofs
or
closed­
vent
systems.

The
required
notifications
are
used
to
inform
the
Agency
or
delegated
authority
when
a
source
becomes
subject
to
the
standard.
The
reviewing
authority
may
then
inspect
the
source
to
check
if
the
floating
roof
or
closed
vent
systems
are
properly
installed
and
operated.
Performance
test
reports
are
needed
as
these
are
the
Agency's
record
of
a
source's
initial
capability
to
comply
with
the
emission
standard,

and
note
the
operating
conditions
under
which
compliance
was
achieved.
The
information
generated
by
the
recordkeeping
and
reporting
requirements
described
in
this
ICR
is
used
by
the
Agency
to
ensure
that
facilities
affected
by
the
NSPS
continue
to
operate
the
control
equipment
used
to
achieve
compliance
with
the
NSPS.

Adequate
recordkeeping,
and
reporting
is
necessary
to
ensure
compliance
with
these
standards,
as
required
by
the
Clean
Air
Act.

The
information
collected
from
recordkeeping
and
reporting
requirements
is
also
6
used
for
targeting
inspections,
and
is
of
sufficient
quality
to
be
used
as
evidence
in
court.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
The
recordkeeping
and
reporting
requested
is
required
under
40
CFR
Part
60
Subpart
Ka.

3(
a)
Nonduplication
If
the
standard
has
not
been
delegated,
the
information
would
have
been
sent
to
the
appropriate
Environmental
Protection
Agency's
Regional
Office.
Otherwise,
the
information
is
sent
directly
to
the
delegated
State
or
Local
Agency.
If
a
State
or
Local
Agency
has
adopted
their
own
similar
regulation
to
implement
the
Federal
Regulation,

a
copy
of
the
report
submitted
to
the
State
or
Local
Agency
can
be
sent
to
the
Administrator
in
lieu
of
the
report
required
by
the
Federal
Standard.
Therefore,
no
duplication
exists.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
An
announcement
of
a
public
comment
period
for
the
renewal
of
this
ICR
was
published
in
the
Federal
Register
on
December
22,
2000
(
65
FR
80854);
no
comments
were
received.

3(
c)
Consultations
No
consultations
were
done..

3(
d)
Effects
of
Less
Frequent
Collection
Less
frequent
information
collection
would
decrease
the
margin
of
assurance
7
that
facilities
are
continuing
to
meet
the
required
standards.
Requirements
for
information
gathering
and
recordkeeping
are
useful
techniques
to
ensure
that
good
operation
and
maintenance
practices
are
applied
and
emission
limitations
are
met.
If
the
information
required
by
this
standard
was
collected
on
a
less
frequent
schedule,
the
likelihood
of
detecting
poor
operation
and
maintenance
of
control
equipment
and
noncompliance
would
decrease.

3(
e)
General
Guidelines
None
of
these
reporting
or
recordkeeping
requirements
violate
any
of
the
regulations
established
by
OMB
in
5
CFR
§
1320.6.

3(
f)
Confidentiality
The
required
information
consists
of
emissions
data
and
other
information
that
have
been
determined
not
to
be
private.
However,
any
information
submitted
to
the
Agency
for
which
a
claim
of
confidentiality
is
made
will
be
safeguarded
according
to
the
Agency
policies
set
forth
in
Title
40,
Chapter
1,
Part
2,
Subpart
B
­
Confidentiality
of
Business
Information
(
see
40
CFR
2;
41
FR
36902,
September
1,
1976;
amended
by
43
FR
40000,
September
8,
1978;
43
FR
42251,
September
20,
1978;
44
FR
17674,

March
23,
1979).

3(
g)
Sensitive
Questions
None
of
the
reporting
or
recordkeeping
requirements
contain
sensitive
questions.

4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
SIC
Codes
8
The
respondents
of
the
recordkeeping
and
reporting
requirements
are:

Regulation
SIC
Codes
NAICS
Codes
NSPS
Subpart
Ka
­
Standards
Of
Performance
For
Storage
Vessels
For
Petroleum
Liquids
2911­
2999
32411,
324121,
324122,
324191
and
324199
4(
b)
INFORMATION
REQUESTED
(
i)
Data
Items
All
data
in
this
ICR
that
is
recorded
and/
or
reported
is
required
by
40
CFR
Part
60
NSPS
Subpart
Ka­
Standards
Of
Performance
For
Storage
Vessels
For
Petroleum
Liquids.

A
source
must
make
the
following
reports.

Reports
for
NSPS
Subpart
Ka
Construction/
reconstruction.
60.7(
a)(
1)

Anticipated
startup.
60.7(
a)(
2)

Actual
startup.
60.7(
a)(
3)

Physical
or
operational
change.
60.7(
a)(
4)

Initial
performance
test.
60.8(
d)

Information
prior
to
construction
on
vapor
recovery
and
return
or
disposal
system
including
emissions
data,
operations
design
specifications
and
maintenance
plan.
60.113a
(
a)(
2)(
i­
iv)

Notification
of
30
days
prior
to
seal
gap
measurement.
60.113a
(
a)(
1)(
iv)

Report
within
60
days
when
a
seal
gap
measurement
exceeds
the
limits
of
60.112a.
60.113a
(
a)(
1)(
i)(
E)

A
source
must
keep
the
following
records.
9
Recordkeeping
for
NSPS
Subpart
Ka
Records
are
required
to
be
retained
for
2
Years.
60.2
Records
startup,
shutdowns,
malfunctions.
60.7(
b)

Records
gap
measurements:
Secondary
seals
every
year
and
Primary
seals
every
five
years.
60.113a
(
a)(
1)(
i)(
D)

Whenever
the
liquid
is
changed
or
stored:
period
of
storage,
type
of
liquid
and
true
vapor
pressure.
60.115a
(
a)

ii.
Respondent
Activities
Respondent
Activities
Read
instructions.

Measure
floating
roof
seals
(
gap
measurement).

Review
vapor
recovery
system.

Record
change
in
liquid,
date
liquid
was
stored,
maximum
true
vapor
pressure.

Provide
information
on
vapor
recovery
and
return
or
disposal
system,
including
emissions
data,
operations
design
specifications
and
maintenance
plan.

Write
the
notifications
and
reports
identified
above.

Enter
information
required
to
be
recorded
above.

Submit
the
required
reports
developing,
acquiring,
installing,
and
utilizing
technology
and
systems
for
the
purpose
of
collecting,
validating,
and
verifying
information.

Develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purpose
of
processing
and
maintaining
information.

Develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purpose
of
disclosing
and
providing
information.

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

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

Transmit,
or
otherwise
disclose
the
information.
10
5.
The
Information
Collected
­­
Agency
Activities,
Collection
Methodology,
and
Information
Management
5(
a)
Agency
Activities
EPA
conducts
the
following
activities
in
connection
with
the
acquisition,
analysis,

storage,
and
distribution
of
the
required
information.

Agency
Activities
Observe
initial
performance
tests
(
no
longer
performed).

Review
notifications
and
reports.

Audit
facility
records.

Input,
analyze,
and
maintain
data
in
the
Aerometric
Information
Retrieval
System
(
AIRS)
database.

5(
b)
Collection
Methodology
and
Management
Following
notification
of
startup,
the
reviewing
authority
might
inspect
the
source
to
determine
whether
the
pollution
control
devices
are
properly
installed
and
operated.

The
Agency
uses
the
performance
test
reports
to
discern
a
source's
initial
capability
to
comply
with
the
emission
standard,
and
note
the
operating
conditions
under
which
compliance
was
achieved.
Data
and
records
maintained
by
the
respondents
are
tabulated
and
published
for
use
in
compliance
and
enforcement
programs.
The
semiannual
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.

Information
contained
in
the
reports
is
entered
into
AIRS
which
is
operated
and
maintained
by
EPA's
Office
of
Air
Quality
Planning
and
Standards.
AIRS
is
EPA's
11
database
for
the
collection,
maintenance,
and
retrieval
of
compliance
and
annual
emission
inventory
data
for
more
than
100,000
industrial
and
government­
owned
facilities.
The
EPA
uses
AIRS
for
tracking
air
pollution
compliance
and
enforcement
by
Local
and
State
regulatory
agencies,
and
EPA
Regional
Offices
and
Headquarters.

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

The
records
required
by
this
regulation
must
be
retained
by
the
owner
or
operator
for
two
years.

5(
c)
Small
Entity
Flexibility
There
are
few
small
businesses
affected
by
this
standard.
The
recordkeeping
and
reporting
requirements
were
selected
within
the
context
of
this
specific
Subpart
and
the
specific
process
equipment
and
pollutant(
s).
The
impact
on
small
businesses
was
accounted
for
in
the
regulation
development.
The
requirements
reflect
the
burden
on
small
businesses.
Even
though,
the
recordkeeping
and
reporting
requirements
are
the
same
for
small
and
larger
businesses.
To
the
extent
that
larger
businesses
can
use
economies
of
scale
to
reduce
their
burden,
the
overall
burden
will
be
reduced.
The
Agency
considers
these
requirements
the
minimum
needed
to
ensure
compliance
and,

therefore,
cannot
reduce
them
further
for
small
businesses.

5(
d)
Collection
Schedule
The
specific
frequency
for
each
information
collection
activity
within
this
request
is
shown
in
Section
6(
d),
Table
2:
Industry
Burden.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
Section
6(
d),
Table
2
documents
the
computation
of
individual
burdens
for
the
12
recordkeeping
and
reporting
requirements
applicable
to
the
industry
for
this
Subpart.

The
individual
burdens
are
expressed
under
standardized
headings
believed
to
be
consistent
with
the
concept
of
burden
under
the
Paperwork
Reduction
Act.
Where
appropriate,
specific
tasks
and
major
assumptions
have
been
identified
in
this
ICR.

Responses
to
this
information
collection
are
mandatory.
(
See
Section
4(
b)(
i).
The
Agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.

The
burden
to
the
Agency
can
be
found
at
Section
6(
c),
Table
1.

6(
a)
Estimating
Respondent
Burden
The
average
annual
burden
to
industry
over
the
next
three
years
from
these
recordkeeping
and
reporting
requirements
is
estimated
at
39,139
person­
hours.
These
hours
are
based
on
Agency
studies
and
background
documents
from
the
development
of
the
standards
or
test
methods,
Agency
knowledge
and
experience
with
the
NSPS
program,
the
previously
approved
ICR,
and
any
comments
received.

6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
This
ICR
uses
$
49.62
per
hour
for
Technical
labor
cost
includes
a
110%

overhead.
This
rate
is
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
Table
1­
1.
Summary,
United
States:
Mean
hourly
earnings
and
weekly
hours
by
selected
characteristics,
private
industry
and
State
and
local
government,
National
Compensation
Survey,
1998,
published
September
2000.
from
the
United
States
Department
of
Commerce
Bureau
of
Labor
Statistics,
March
1999,
Table
10:
13
Employment
Costs
for
Private
Industry
by
Occupational
and
Industry
Group.
The
rates
are
from
column
1:
Total
compensation.
The
wage
rate
includes
a
110%
overhead
cost.

(
ii)
Estimating
Capital
and
Operations
and
Maintenance
Costs
The
only
type
of
industry
cost
associated
with
the
information
collection
activity
in
the
standards
is
labor
cost.
There
are
no
capital
or
operations
and
maintenance
costs.
The
capital
startup
costs
are
a
one
time
cost
when
a
facility
becomes
subject
to
the
standard.
The
annual
operations
and
maintenance
costs
are
the
ongoing
costs
to
maintain
the
emission
control
equipment.

(
iii)
Capital/
Start­
up
vs.
Operating
and
Maintenance
(
O&
M)
Costs
There
is
no
continuous
monitoring
requirement(
s)
for
NSPS
Subpart
Ka.

The
total
Capital/
Start­
up
costs
for
this
ICR
are
$
0.
This
cost
is
shown
on
the
OMB
83­
I
form
in
block
14
letter
a:
Total
annualized
capital/
startup
costs.

The
total
Operating
and
Maintenance
(
O&
M)
Costs
for
this
ICR
is
$
0.
This
cost
is
shown
on
the
OMB
83­
I
form
in
block
14
letter
b:
Total
annual
costs
(
O&
M).

The
total
respondent
costs
have
been
calculated
on
the
addition
of
the
capital
start
up
costs
and
the
annual
operations
and
maintenance
costs.
The
average
annual
cost
for
capital
and
operations
and
maintenance
costs
to
industry
over
the
next
three
years
of
the
ICR
are
estimated
to
be
$
0.
This
cost
is
shown
on
the
OMB
83­
I
form
in
block
14
letter
c:
Total
annualized
cost
requested.
The
numbers
in
block
14
of
the
OMB
83­
I
form
are
truncated
to
show
the
cost
in
thousands
of
dollars.
14
The
only
Federal
costs
are
user
costs
associated
with
analysis
of
the
reported
information.
Publication
and
distribution
of
the
information
are
part
of
the
AIRS
program.
Periodic
inspection
of
affected
sources
includes
the
examination
of
records
maintained
by
the
respondents,
which
is
part
of
the
EPA's
overall
compliance
and
enforcement
program.

The
average
annual
Federal
Government
cost
during
the
three
years
of
the
ICR
is
estimated
to
be
$
7,775.
This
cost
is
based
on
an
average
wage
of
a
GS
10
­
step1
employee
is
$
17.55
hr
+
110%
overhead
=
$
36.85.
This
rate
is
from
OPM's
2001
General
Schedule,
excluding
locality
pay.
15
6(
c)
Table
1
­
Estimating
Agency
Burden
and
Cost
as
a
Result
of
NSPS
Subpart
Ka,
Standards
Of
Performance
For
Storage
Vessels
For
Petroleum
Liquids
a
EPA
Occurrences/
EPA
Plants/
EPA
hr/
occurrence
plant/
year
hr/
plant/
year
year
hr/
yr
(
A)
(
B)
(
C=
AxB)
(
D)
(
CxD)

Report
Review:
New
Plant
Vapor
recovery
information
b
Report
Review:
Existing
Plant
Notification
of
reconstruction
2.0
1.0
2.0
0
0
Notification
of
modification
2.0
1.0
2.0
0
0
Notification
of
seal
gap
0.5
1.0
0.5
174
x
0.9c
78
measurement
Report
of
gap
excesses
1.0
1.0
1.0
174
x
0.9c,
d
157
ANNUAL
HOURS
FOR
Subpart
Ka
235
10%
Using
the
CAR
Rule
f
24
TOTAL
ANNUAL
HOURS
211
Travel
Expenses
(
Ten
people
[
1
from
each
Region]
x
0
plants/
yr
x
3
days/
plant
x
$
42
per
diem
x
$
90
lodging)
+
($
450
travel
ticket/
plant
x
0
plant
day)
=
$
0/
yr
Salary
(
Ten
people
[
1
from
each
Region]
x
24.8e
hr/
year
x
$
36.85/
hr)
=
$
7,775/
yr
TOTAL
ANNUAL
COST
$
7,775/
yr
a
Assume
no
new
sources
subject
to
this
regulation.
All
new
sources
will
be
subject
to
Subpart
Kb.

b
Required
only
at
start
of
construction.
This
is
a
closed
regulation.
Any
new
storage
vessels
being
constructed
would
be
subject
to
the
NSPS
Subpart
Kb.

c
Assume
that
90%
of
the
storage
vessels
will
use
a
floating
roof.
The
remaining
10%
will
use
a
closed
vent
system.

d
Each
respondent
is
assumed
to
manage
approximately
50
tanks
subject
to
Subpart
Ka.
Assume
that
a
number
of
the
average
50
tanks
per
Respondent
using
a
floating
roof
will
have
excessive
seal
gaps
requiring
that
a
single
report
be
filed
once
per
year.

e
Assume
the
labor
rate
to
be
GS­
10,
Step
1
@
$
17.55
x
110%=$
36.85
per
FY
2001
Pay
Scale
excluding
locality
pay.

f
Percentage
(
10%)
of
Ka
respondents
utilizing
the
Consolidated
Air
Rule­
OMB
Number
2060­
0443.
16
6(
d)
Table
2
­
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
as
a
Result
of
NSPS
Subpart
Ka,

Standards
Of
Performance
For
Storage
Vessels
For
Petroleum
Liquids
Occurrences/
Hours/

Hours/
respondent/
respondent/
Respondents/
Hours/
Cost/

Occurrence
year
year
year
year
year
(
A)
(
B)
(
C=
AxB)
(
D)
(
E=
CxD)
(
F)
b
1.
Applications
....................................
not
applicable............................................

2.
Surveys
and
Studies
....................................
not
applicable............................................

3.
Reporting
Requirements
A.
Read
Instructions
Included
in
3B
B.
Required
Activities
Vapor
recovery
information
20
1
20
0
0
0
Measure
seal
gap
Included
in
4E.

C.
Create
Information
Included
in
3B.

D.
Gather
Existing
Information
1
1
1
174
x
0.9
157
7,790
E.
Write
Report
Notification
of
construction/
2
1
2
0
0
0
reconstruction
Notification
of
anticipated
2
1
2
0
0
0
startup
Notification
of
actual
startup
2
1
2
0
0
0
Notification
of
gap
measurement
1.5
1
1.5
174
x
0.9c
235
11,661
Report
of
seal
gap
excess
2.5
1
2.5
174
x
0.9c
392
19,451
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
System
....................................
not
applicable............................................

E.
Time
to
Enter
Information
New
tank
seal
gap
measurements
5
x
50
1
250
0
0
0
Secondary
seal
gap
measurements
5
x
50d,
e
1
250
174
x
0.9c
39,250
1,947,585
17
6(
d)
Table
2
­
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
as
a
Result
of
NSPS
Subpart
Ka,

Standards
Of
Performance
For
Storage
Vessels
For
Petroleum
Liquids,
cont.

Occurrences/
Hours/

Hours/
respondent/
respondent/
Respondents/
Hours/
Cost/

Occurrence
year
year
year
year
year
(
A)
(
B)
(
C=
AxB)
(
D)
(
E=
CxD)
(
F)
b
Primary
seal
gap
measurements
2
x
50d,
e
0.2
f
20
174
x
0.9c
3,140
155,807
Fill/
refill
record
.20
x
10g
1
2
174
x
0.9c
314
15,581
F.
Train
Personnel
....................................
not
applicable............................................

G.
Audits
....................................
not
applicable............................................

ANNUAL
BURDEN
43,488
$
2,157,875
10%
Using
the
CAR
Rule
h
4,349
215,787
TOTAL
ANNUAL
BURDEN
39,139
1,942,077
a
Assume
that
there
will
be
no
new
sources
subject
to
the
requirements
of
this
regulation.
New
sources
will
be
subject
to
NSPS
Subpart
Kb.

b
Assume
an
hourly
wage
of
$
49.62
which
includes
the110%
overhead
cost.
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,

Table
1­
1.
Summary,
United
States:
Mean
hourly
earnings
and
weekly
hours
by
selected
characteristics,
private
industry
and
State
and
local
government,
National
Compensation
Survey,
1998,
published
September
2000.

c
Estimate
that
10%
of
respondents
will
use
a
vapor
recovery
control
system
and
the
balance
(
90%)
will
use
a
floating
roof
system.
Respondents
using
vapor
recovery
control
are
not
required
to
do
seal
gap
measurements.

d
There
is
an
approximate
average
of
50
tanks
subject
to
Subpart
Ka
per
respondent.
Assume
that
a
number
of
tanks
per
every
respondent
using
a
floating
roof,
will
have
excessive
seal
gaps
requiring
that
a
single
report
be
filed
once
a
year.

e
Estimate
five
hours
to
conduct
secondary
seal
measurements
annually
for
an
average
50
tanks
per
respondent.

f
Estimate
two
hours
to
conduct
primary
seal
measurements
every
five
years.

g
Assume
that
any
one
tank
would
be
emptied
on
average
once
every
five
years,
and
then
required
to
report
a
liquid
change.
During
any
one
year,
a
respondent
would
change
liquid
in
approximately
10
tanks
or
20%
of
the
50
tank
average
at
each
facility.

h
Percentage
(
10%)
of
Ka
respondents
utilizing
the
Consolidated
Air
Rule­
OMB
Number
2060­
0443.

Notifications:

1.
90%
of
respondents
will
notify
yearly
on
secondary
seal
gap
measurements
taking
place
157
2.
3%
of
157
notifications
will
need
to
report
secondary
seal
gap
exceedance
5
3.
For
primary
gap
measures,
20%
of
respondents
will
conduct
31
4.
Of
the
31
respondents,
1%
will
need
to
report
exceeding
any
primary
seal
gap.
1
5.
20%
of
respondents
will
notify
that
they
are
fill/
refill
storage
vessels
31
18
Total
number
of
annual
responses
225
The
total
number
of
affected
sources
is
157.
It
is
shown
on
the
OMB
83­
I
form
in
block
13
a.
This
is
the
number
of
existing
sources
subject
the
NSPS
Subpart
Ka.

The
total
number
of
annual
responses
was
174.
Ninety
percent
of
the
respondents
(
157)

will
notify
annually
on
the
secondary
gap
measure,
5
notifications
will
be
received
due
to
exceeding
the
secondary
gap
and
31
notifications
will
be
received
for
primary
gap
notifications,

1
notification
for
exceeding
the
primary
seal
gap
and
31
notifications
for
fill/
refill.
It
is
estimated
that
10%
of
the
total
annual
potential
responses
will
comply
with
the
Consolidated
Air
Rule
for
the
SOCMI
Industry
(
174
x
10%
=
17
responses).
This
number
is
shown
on
the
OMB
83­
I
form
in
block
13
b.
The
total
annual
labor
costs
are
$
2,181,783.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
13
c.

The
total
annual
capital
and
O&
M
costs
to
the
regulated
entity
are
$
0.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
14
c.

6(
e)
Bottom
Line
Burden
Hours
And
Cost
Tables
See
Section
6(
c),
Table
1,
EPA's
Burden
for
complete
details.
In
summary,
the
burden
to
the
Agency
is
211
hours
at
a
cost
of
$
7,775
a
year.
Section
6(
d),
Table
2,
Respondents'

Burden
has
the
complete
details
for
industry.
In
summary,
the
burden
to
industry
is
39,139
hours
at
a
cost
of
$
2,181,783
per
year.

6(
f)
Reasons
for
Change
in
Burden
There
is
a
change
in
the
burden
hours.
The
currently
approved
OMB
Inventory
for
Burden
Hours
for
Subpart
Ka
is
43,514.
This
ICR
now
includes
a
10%
decrease
due
to
respondents
opting
out
of
NSPS
Subpart
Ka
and
taking
advantage
of
the
Consolidated
Air
19
Rule.
The
respondents
taking
advantage
of
the
Consolidated
Air
Rule
reduces
the
total
burden
assigned
to
NSPS
Ka
by
4,341
hours
for
a
total
of
39,139
burden
hours.

6(
g)
Burden
Statement
Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.
An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
Part
9
and
48
CFR
Chapter
15.

Send
comments
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
a
respondent's
burden,
including
through
the
use
of
automated
collection
techniques
to
the
Director,
Collection
Strategies
Division,
Office
of
Environmental
Information
(
OEI),
U.
S.
Environmental
Protection
Agency,

Mail
Code
2822,
1200
Pennsylvania
Avenue,
NW,
Washington,
D.
C.
20460­
0001;
and
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
D.
C.
20503,
Attention:
Desk
Officer
for
EPA.
Include
the
EPA
ICR
number
1050.07
and
OMB
control
number
2060­
0121
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
20
information.
