SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
STANDARDS
OF
PERFORMANCE
NSPS
SUBPART
GGG
EQUIPMENT
LEAKS
OF
VOC
IN
PETROLEUM
REFINERIES
1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
ICR
for
NSPS
Subpart
GGG
­
Equipment
Leaks
of
VOC
in
Petroleum
Refineries
1(
b)
Short
Characterization/
Abstract
The
New
Source
Performance
Standards
(
NSPS)
for
Equipment
Leaks
of
VOC
(
Volatile
Organic
Compound)
in
Petroleum
Refineries
were
proposed
on
January
4,
1983
and
promulgated
on
May
30,
1984.
These
standards
apply
to
the
following
facilities
in
petroleum
refineries:
compressors
and
the
group
of
all
equipment
(
e.
g.,
valves,
pumps,
flanges,
etc.)
within
a
process
unit
in
VOC
service,
commencing
construction,
modification
or
reconstruction
after
the
date
of
proposal.
This
information
is
being
collected
to
assure
compliance
with
40
CFR
Part
60
Subpart
GGG.

Owners
or
operators
of
the
affected
facilities
described
must
make
one­
time­
only
notifications.
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.
Monitoring
requirements
specific
to
Equipment
Leaks
of
VOC
in
Petroleum
Refineries
provide
information
on
which
components
are
leaking
VOCs.
NSPS
GGG
references
the
compliance
requirements
of
NSPS
VV.
Owners
or
operators
are
required
to
periodically
(
time
period
varies
depending
on
equipment
type
and
leak
history)
record
information
identifying
leaking
equipment,
repair
methods
used
to
stop
the
leaks
and
dates
of
repair.
Semiannual
reports
are
required
to
measure
compliance
with
the
standards
of
NSPS
Subpart
VV
as
referenced
by
NSPS
Subpart
GGG
.
These
notifications,
reports,
and
records
are
essential
in
determining
compliance;
and
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
following
the
date
of
such
measurements,
maintenance
reports,
and
records.

The
Environmental
Protection
Agencies
databases
show
that
approximately
45
sources
are
currently
subject
to
the
standard,
and
it
is
estimated
that
an
additional
3
sources
per
year
will
become
subject
to
the
standard
in
the
next
three
years.
There
have
been
no
new
refineries
built
during
the
period
of
these
regulations,
and
the
increase
is
expected
to
come
solely
from
sources
that
meet
the
definition
of
reconstruction
or
modification.
The
labor
hours
are
6,137
per
year
and
the
annual
cost
of
this
ICR
will
be
$
340,021.
All
reports
are
sent
to
the
delegated
State
or
2
Local
authority.
In
the
event
that
there
is
no
such
delegated
authority,
the
reports
are
sent
directly
to
the
EPA
Regional
Office.

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
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
methods
at
such
locations,
at
such
intervals,
during
such
periods,
and
in
such
manner
as
the
Administrator
shall
prescribe);
(
E)
keep
records
on
control
equipment
parameters,
production
variables
or
other
indirect
data
when
direct
monitoring
of
emissions
is
impractical;
(
F)
submit
compliance
certifications
in
accordance
with
Section
114(
a)(
3);
and
(
G)
provide
such
other
information
as
the
Administrator
may
reasonably
require.

In
the
Administrator's
judgment,
VOC
emissions
from
Equipment
Leaks
of
VOC
in
Petroleum
Refineries
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
NSPS
were
promulgated
for
this
source
category
at
40
CFR
Part
60,
Subpart
GGG.

2(
b)
PRACTICAL
UTILITY/
USERS
OF
THE
DATA
The
control
of
emissions
of
VOC
from
equipment
leaks
of
VOC
in
petroleum
refineries
requires
not
only
the
installation
of
properly
designed
equipment,
but
also
the
operation
and
maintenance
of
that
equipment.
Emissions
of
VOC
from
equipment
leaks
in
petroleum
refineries
are
the
result
of
operation
of
the
compressors
and
the
group
of
all
equipment
(
e.
g.,
valves,
pumps,
flanges,
etc.)
within
a
process
unit
in
VOC
service.
These
standards
rely
on
the
prevention
of
VOC
emissions
by
the
work
practice
of
proper
leak
detection
and
timely
repair.
The
notifications
required
in
these
standards
are
used
to
inform
the
Agency
or
delegated
authority
when
a
source
3
becomes
subject
to
these
standards.
The
reviewing
authority
may
then
inspect
the
source
to
check
if
the
leaks
are
being
detected
and
repaired
and
the
standard
is
being
met.
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
serve
as
a
record
of
the
operating
conditions
under
which
compliance
was
achieved.
NSPS
Subpart
GGG
references
NSPS
Subpart
VV
for
compliance.
Monthly
monitoring
of
compressors
and
equipment
in
VOC
service
under
NSPS
Subpart
GGG
shall
take
place
as
specified
in
NSPS
Subpart
VV
section
60.485(
b).
For
valves,
if
no
leaks
are
detected
for
two
successive
months,
monitoring
may
be
performed
once
per
quarter
(
see
§
60.482­
7(
c)).
If
a
leak
is
detected,
the
equipment
shall
be
monitored
monthly
until
a
leak
is
not
detected
for
two
successive
months.
Also,
leak
location
shall
be
recorded
in
a
log,
and
this
information
shall
be
kept
available
for
two
years.
Leaks
shall
be
repaired
within
15
days
and
the
date
of
successful
repair
shall
be
recorded
in
the
log.
Additionally,
an
owner
or
operator
may
use
specified
equipment
eliminating
the
need
for
monitoring,
or
seek
approval
of
alternative
emission
limitations
under
other
various
sections
of
40
CFR
Subpart
VV.
Semiannual
reports
shall
be
submitted
itemizing
the
information
for
each
month.
Notifications
are
used
to
inform
the
Agency,
or
delegated
authority
when
a
source
becomes
subject
to
a
standard.
The
reviewing
authority
may
then
inspect
the
source
to
check
if
the
standard
is
being
met.
The
semiannual
reports
are
used
for
problem
identification,
as
a
check
on
source
operations
and
maintenance,
and
for
compliance
determinations.
The
information
generated
by
the
monitoring,
recordkeeping
and
reporting
requirements
described
in
this
ICR
is
used
by
the
Agency
to
ensure
that
facilities
affected
by
the
NSPS
continue
to
identify
and
repair
leaking
equipment
and
achieve
compliance
with
the
regulation.
Adequate
monitoring,
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
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
GGG.

3(
a)
Nonduplication
If
the
subject
standards
have
not
been
delegated,
the
information
is
sent
to
the
appropriate
EPA
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
standards
to
implement
the
Federal
standards,
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
standards.
Therefore,
no
duplication
exists.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
An
announcement
of
a
public
comment
period
for
the
renewal
of
this
ICR
was
published
in
the
Federal
Register
on
January
30,
2002.
No
comments
were
received
on
the
burden
published
4
in
the
Federal
Register.

3(
c)
Consultations
The
National
Petroleum
Refiners
Association
and
the
American
Petroleum
Institute
were
consulted
regarding
industry
growth
rate,
current
number
of
facilities
and
the
number
of
new
affected
facilities
over
the
next
three
years.
They
relayed
that
the
assumptions
and
information
presented
in
this
ICR
seem
appropriate.

3(
d)
Effects
of
Less
Frequent
Collection
Less
frequent
information
collection
would
decrease
the
margin
of
assurance
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
these
standards
was
collected
less
frequently,
the
likelihood
of
detecting
poor
operation
and
maintenance
of
control
equipment
and
noncompliance
would
decrease.

3(
e)
General
Guidelines
None
of
the
reporting
or
recordkeeping
requirements
contained
in
40
CFR
Part
60
Subpart
GGG
or
otherwise
pertinent
to
this
request
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
contained
in
40
CFR
Part
60,
Subpart
GGG
or
otherwise
pertinent
to
this
request
contain
sensitive
questions.

4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
SIC
Codes
The
respondents
of
the
recordkeeping
and
reporting
requirements
are
petroleum
refineries
5
where
the
affected
compressors
or
group
of
equipment
within
a
process
unit
commenced
construction,
modification,
or
reconstruction
after
January
4,
1983.
The
SIC
code
for
the
respondents
affected
by
the
standards
is
SIC
(
U.
S.
Standard
Industrial
Classification)
Code
2911
which
corresponds
to
the
NAICS
(
North
American
Industry
Classification
System)
324110
for
petroleum
refineries
where
the
affected
compressors
or
group
of
equipment
within
a
process
unit
commenced
construction,
modification,
or
reconstruction
after
January
4,
1983.

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,
Subpart
GGG.
Although
monitoring
of
the
various
components
may
be
required
on
a
weekly,
monthly,
quarterly,
semi
annual
or
annual
basis,
given
the
number
of
components
that
must
be
monitored
at
any
facility,
monitoring
overall
is
essentially
occurring
daily.
Therefore,
it
is
assumed
that
the
average
record
keeping
time
for
each
day's
worth
of
monitoring
is
0.3
hours
and
that
monitoring
is
done
365
days
a
year.

A
source
must
make
the
following
reports:

Notifications
for
40
CFR
Part
60,
Subpart
GGG
Citation
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)

Alternative
standard
selected
60.487(
d)

Reports
for
40
CFR
Part
60,
Subpart
GGG
Initial
performance
test
results
60.8(
a)

Comply
with
the
provisions
of
60.487
60.592(
e)

Semiannual
reports
60.486,
60.487(
a),
60.487(
b),
60.487(
c)

Performance
test
60.8,
60.487(
e)

A
source
must
keep
the
following
records.
6
Recordkeeping
for
40
CFR
Part
60,
Subpart
GGG
Citation
Startups,
shutdowns,
malfunctions
60.7(
b)

All
measurements,
monitoring
device,
and
performance
testing
measurements
60.7(
e)

Comply
with
the
provisions
of
60.486
60.592(
e)

Each
detected
leak
shall
be
recorded
in
a
log
and
kept
for
2
years
60.486(
c)

Information
pertaining
to
design
requirements
or
closed
vent
systems
and
control
devices
60.486(
d)

Information
pertaining
to
all
equipment
60.486(
e)

Information
pertaining
to
all
valves
60.486(
f)

Information
pertaining
to
valves
complying
with
alternative
compliance
requirements
60.486(
g)

Design
criteria
and
any
changes
60.486(
h)

Records
for
use
in
determining
exemptions
60.486(
i)

Information
and
data
to
demonstrate
that
a
piece
of
equipment
is
not
in
VOC
service
60.486(
j)

Records
are
required
to
be
retained
for
2
years.

ii.
Respondent
Activities
Respondent
Activities
Read
instructions
Perform
initial
performance
test
as
per
40
CFR
60.485,
Reference
Method
21
and
22
tests,
and
repeat
performance
tests
Write
the
notifications
and
reports
listed
above
Enter
information
required
to
be
recorded
above
Submit
the
required
reports
developing,
acquiring,
installing,
and
utilizing
technology
and
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
7
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
As
refiners
replace/
upgrade
their
monitoring
equipment,
they
may
choose
to
use
systems
that
automatically
log
the
results
of
monitoring,
which
can
then
be
downloaded
into
a
computer
database.
This
database
can
then
be
used
to
develop
the
required
reports.

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
information
required
under
40
CFR
Subpart
GGG:

Agency
Activities
Observe
initial
performance
tests
and
repeat
performance
tests
if
necessary
Review
notifications
and
reports,
including
performance
test
reports,
and
other
reports,
required
to
be
submitted
by
industry
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.
Performance
test
reports
are
used
by
the
Agency
to
discern
a
source's
initial
capability
to
comply
with
the
emission
standard.
Data
and
records
maintained
by
the
respondents
are
tabulated
and
published
for
use
in
compliance
and
enforcement
programs.
The
semiannual
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
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
database
for
the
collection,
maintenance,
and
retrieval
of
compliance
and
annual
emission
inventory
data
for
8
over
100,000
industrial
and
government­
owned
facilities.
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
For
this
industry
there
is
a
distribution
of
business
sizes.
The
recordkeeping
and
reporting
requirements
were
selected
within
the
context
of
this
specific
subpart
and
the
specific
process
equipment
and
pollutant.
A
majority
of
the
affected
facilities
are
large
businesses.
However,
the
impact
on
small
businesses
was
taken
into
consideration
during
development
of
the
regulation.
Due
to
technical
considerations
involving
the
process
operations
and
leak
detection
and
repair
programs,
the
recordkeeping
and
reporting
requirements
are
the
same
for
both
small
and
large
businesses.
The
Agency
considers
these
requirements
to
be
the
minimum
needed
to
ensure
compliance
and,
therefore,
cannot
reduce
them
further
for
small
businesses.
To
the
extent
that
larger
businesses
can
use
economies
of
scale
to
reduce
their
burden,
the
overall
burden
will
be
reduced.

For
sources
that
install
"
leakless"
components,
monitoring
may
not
be
required
for
those
components.
Monitoring
(
therefore,
recordkeeping)
may
also
be
reduced
for
sources
that
maintain
low
percentages
of
leaking
components.
Additionally,
alternative
means
of
emission
limitation
are
allowed
after
proper
demonstration
of
their
effectiveness
to
the
Administrator.

5(
d)
Collection
Schedule
The
specific
frequency
for
each
information
collection
activity
within
this
request
is
shown
in
Table
2:
Annual
burden
of
reporting
and
recordkeeping
requirements
as
a
result
of
NSPS
Subpart
GGG.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
Table
2
documents
the
computation
of
individual
burdens
for
the
recordkeeping
and
reporting
requirements
applicable
to
the
industry
for
the
Subpart
included
in
this
ICR.
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.
The
type
of
industry
costs
associated
with
the
information
collection
activity
in
the
standards
are
labor
costs
for
using
the
VOC
monitors.
Monitoring
equipment
for
leaks
is
standard
in
the
industry
for
safety
reasons.
To
the
extent
possible,
the
requirements
of
this
standard
are
consistent
with
industry
practice.
Consequently,
there
are
no
capital
costs
associated
with
this
standard.
Responses
to
this
information
collection
are
mandatory.
The
Agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.

6(
a)
Estimating
Respondent
Burden
The
average
annual
burden
to
industry
over
the
next
three
years
from
these
recordkeeping
9
and
reporting
requirements
is
estimated
at
6,137
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
labor
rates
of
$
55.34
per
hour
for
technical
(
most
activities)
and
$
78.54
per
hour
for
managerial
(
assumed
needed
only
for
performance
tests).
These
rates
are
from
the
United
States
Department
of
Commerce
Bureau
of
Labor
Statistics,
March
2000,
"
Table
10.
Private
industry,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
wage
rates
have
been
increased
by
110%
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.

(
ii)
Estimating
Capital
and
Operations
and
Maintenance
Costs
The
only
type
of
industry
costs
associated
with
the
information
collection
activity
in
the
standards
are
labor
costs.
There
are
no
capital/
startup,
or
operation
and
maintenance
costs.
The
type
of
industry
costs
associated
with
the
information
collection
activity
in
the
standards
are
labor
costs
and
maintenance
costs
for
the
VOC
monitors.
Monitoring
equipment
for
leaks
is
standard
in
the
industry
for
safety
reasons.
To
the
extent
possible,
the
requirements
of
this
standard
are
consistent
with
industry
practice.
Consequently,
there
are
no
capital
costs
associated
with
this
standard.

(
iii)
Capital/
Start­
up
vs.
Operating
and
Maintenance
(
O&
M)
Costs
This
is
not
applicable
since
this
is
a
leak
detection
and
repair
program
with
no
continuous
monitoring
equipment
as
stated
in
the
previous
section.

6(
c)
Estimating
Agency
Burden
and
Cost
The
only
costs
to
the
Agency
are
those
costs
associated
with
analysis
of
the
reported
information.
Publication
and
distribution
of
the
information
are
part
of
the
AFS
program.
Examination
of
records
to
be
maintained
by
the
respondents
will
occur
as
part
of
the
periodic
inspection
of
sources,
which
is
part
of
EPA's
overall
compliance
and
enforcement
program.

The
average
annual
Agency
cost
during
the
3
years
of
the
ICR
is
estimated
to
be
$
20,060
(
from
table
1).
This
cost
is
based
on
the
average
hourly
labor
rate
at
a
GS12
step
1
times
a
1.6
benefits
multiplication
factor
to
account
for
government
overhead
expenses
for
a
total
of
$
36.98.
Details
upon
which
this
estimate
is
based
appear
in
Table
1:
Average
annual
EPA
resource
requirements
resulting
from
NSPS
Subpart
GGG.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
10
Respondent
Universe:

Regulation
Citation
(
A)
No.
of
New
Source/
Year
(
B)
No.
of
Initial
Reports
for
New
Sources
(
C)
No.
of
Existing
Sources
(
D)
No.
of
Reports
for
Existing
Sources
(
E)
Total
Annual
Responses
(
AxB)+(
CxD)

40
CFR
Part
60,
Subpart
GGG
3
4
45
2
102
The
number
of
total
respondents
is
48.
This
number
is
the
sum
of
Column
A
and
Column
C
of
the
Respondent
Universe
table
above.
This
represents
the
number
of
existing
sources
plus
the
number
of
new
sources
averaged
over
the
three­
year
period.
It
is
shown
in
block
13(
a),
Number
of
respondents,
on
the
OMB
83­
I
form.

The
number
of
Total
Annual
Responses
is
102.
This
is
the
number
in
column
E
of
the
Respondent
Universe
table.
It
is
shown
in
block
13(
b),
Total
annual
responses,
on
the
OMB
83­
I
form.
The
total
annual
labor
costs
are
$
340,021.
This
number
is
not
shown
on
the
OMB
83­
I
form
on
block
13(
c),
Total
hours
requested.
Only
the
burden
hours
are
reflected
in
block
13(
c).
Details
upon
which
this
estimate
is
based
appear
in
Table
2.
Annual
burden
of
reporting
and
recordkeeping
requirements
as
a
result
of
NSPS
Subpart
GGG.

The
total
annual
capital
and
O&
M
costs
to
the
regulated
entity
are
zero
dollars.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
14
(
c),
Total
annualized
cost
requested.
Capital
and
O&
M
costs
are
not
applicable
since
this
is
a
leak
detection
and
repair
program
with
no
continuous
monitoring
equipment
used.

6(
e)
Bottom
Line
Burden
Hours
And
Cost
Tables
The
bottom
line
burden
hours
and
cost
table
for
both
the
Agency
and
the
respondents
appear
below
(
Table
1
and
Table
2).

6(
f)
Reasons
for
Change
in
Burden
The
increase
in
burden
cost
from
the
most
recently
approved
ICR
is
due
to
a
change
in
calculated
labor
rates.

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
11
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
respondent
burden,
including
through
the
use
of
automated
collection
techniques
to
the
Director,
Collection
Strategies
Division,
U.
S.
Environmental
Protection
Agency
(
2822T),
1200
Pennsylvania
Avenue,
N.
W.,
Washington,
D.
C.
20460­
0001;
and
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Officer
for
EPA.
Include
the
EPA
ICR
number
and
OMB
control
number
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
TABLE
1:
AVERAGE
ANNUAL
EPA
RESOURCE
REQUIREMENTS
RESULTING
FROM
NSPS
SUBPART
GGG.

Activity
(
A)
EPA
Hours/
Occurrence
(
B)
Occurrences/
Plant/
Y
ear
(
C)
a
EPA
Hours/
Plant
Year
(
D)
Plants/
Year
(
E)
b
EPA
Hours/
Year
Initial
Performance
Tests
(
New
Plants)
24
1
24
3
72
Repeat
Performance
Tests
c
(
New
Plants)
24
0.2
4.8
3
14.4
Report
Review
(
New
Plants)

Notification
of
construction
2
1
2
3
6
Notification
of
anticipated
startup
0.5
1
0.5
3
1.5
Notification
of
actual
startup
0.5
1
0.5
3
1.5
Notification
of
initial
test
0.5
1.2
0.6
3
1.8
Review
test
results
8
1.2
9.6
3
28.8
(
Existing
Plants)

Emission
Reports
4
2
8
51
408
Total
Annual
Hours
534
Travel
Expenses:

(
1
person
x
3
plants/
year
x
3
days/
plant
x
$
50
per
diem)
=
($
250
round
trip/
plant
x
3
plants/
year)
=
$
1200/
year
Salary:
d
(
510
hours/
year
x
$
36.98/
hour)
=
$
18,860/
year
Total
Annual
Cost
=
$
1,200
x
$
18,860
=
$
20,060
a
A
x
B
=
C
b
C
X
D
=
E
c
Assume
20%
of
initial
performance
tests
must
be
repeated
due
to
failure
d
Estimate
an
hourly
wage
of
GS
12
Step
1
multiplied
by
a
1.6
benefits
multiplication
factor
to
account
for
government
overhead
expenses
for
a
total
of
$
36.98
TABLE
2:
ANNUAL
BURDEN
OF
REPORTING
AND
RECORDING
REQUIREMENTS
AS
A
RESULT
OF
NSPS
SUBPART
GGG
a
Hours
per
Occurrence
Occurrences/
Res
pondent/
Year
Hours/
Respondent
/
Year
©
=
A
x
B)
Respondents/
Year
Hours/
Year
(
E
=
C
x
D)
Cost/
Year
1.
APPLICATIONS
(
Not
Applicable)

2.
SURVEY
AND
STUDIES
(
Not
Applicable)

3.
REPORT
REQUIREMENTS
A.
Read
Instructions
1
1
1
3
3
166
c
B.
Required
Activities
Initial
performance
test
24
1
24
3
72
4,319
b
Repeat
performance
test
24
1
24
0.6
d
14
840
b
C.
Create
Information
(
Included
in
3B)

D.
Gather
Existing
Information
(
Included
in
3E)

E.
Write
Report
Notification
of
construction
or
reconstruction
2
1
2
3
6
332
c
Notification
of
anticipated
startup
2
1
2
3
6
332
c
Notification
of
actual
startup
2
1
2
3
6
332
c
Hours
per
Occurrence
Occurrences/
Res
pondent/
Year
Hours/
Respondent
/
Year
©
=
A
x
B)
Respondents/
Year
Hours/
Year
(
E
=
C
x
D)
Cost/
Year
Notification
of
initial
performance
test
2
1
2
3
6
332
c
Report
of
performance
test
(
Included
in
3B)

Semiannual
work
practice
reports
8
2
16
48
e
768
42,501
c
4.
RECORDKEEPING
REQUIREMENTS
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
g
0.3
365
f
109.5
48
e
5,256
290,867
c
F.
Train
Personnel
(
Not
Applicable)

G.
Audits
(
Not
Applicable)
5.
TOTAL
ANNUAL
BURDEN
6,137
$
340,021
a.
Estimating
that
there
are
approximately
9
plants
(
respondents)
which
become
subject
over
a
3­
year
period.
The
number
of
new
sources
per
year
equals
9/
3
=
3.

b.
Assume
an
average
hourly
wage
of
($
55.34
x
0.8E
+
$
78.54
x
0.2E).
This
amount
was
multiplied
by
the
hours
per
year
in
Column
E.

c.
Assume
100%
technical
rate
at
$
55.34/
hour.

d.
Assume
20%
of
initial
performance
tests
must
repeat
due
to
failure.

e.
Assume
operation
is
365
days
per
year
as
specified
in
the
NSPS
review
document.

f.
Assume
that
the
average
number
of
new
affected
facilities
to
be
constructed
or
reconstructed
over
the
next
3
years
(
45
+
9/
3
=
48)

g.
Although
monitoring
of
the
various
components
may
be
required
on
a
weekly,
monthly,
quarterly,
semi­
annual
or
annual
basis,
given
the
number
of
omponents
that
must
be
monitored
at
any
facility,
monitoring
overall
is
essentially
occurring
daily.
Therefore,
it
is
assumed
that
the
average
record
keeping
time
for
each
day's
worth
of
monitoring
is
0.3
hours
and
that
monitoring
is
done
365
days
per
year.
