SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
40
CFR
Part
63,
Subpart
CC
­
National
Emissions
Standards
for
Hazardous
Air
Pollutants
from
Petroleum
Refineries
1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
ICR
for
40
CFR
Part
63,
Subpart
CC
­
National
Emissions
Standards
for
Hazardous
Air
Pollutants
from
Petroleum
Refineries.

1(
b)
Short
Characterization/
Abstract
!
Type
of
collection
is
periodic
report,
test
data,
and
recordkeeping;

!
The
Regional
Offices
collect
the
data;

!
Respondents
are
required
to
submit
one­
time
reports
of
start
of
construction,

anticipated
and
actual
start­
up
dates,
and
physical
or
operational
changes
to
existing
facilities.
In
addition,
subpart
CC
would
require
respondents
to
submit
three
types
of
reports:
(
1)
Notification
of
Compliance
Status,
(
2)
Periodic
Reports
and
(
3)
Other
event
triggered
reports.
The
Notification
of
Compliance
Status
is
submitted
to
provide
the
information
necessary
to
demonstrate
that
compliance
has
been
achieved.
The
Periodic
Reports
provide
information
on
monitored
control
device
parameters
when
they
are
outside
of
established
ranges
and
information
on
instances
where
inspections
revealed
problems.
In
addition,
respondents
are
required
to
comply
with
the
recordkeeping
and
reporting
requirements
contained
in
either
40
CFR
61
subpart
VV
or
40
CFR
63
subpart
H
for
equipment
leaks
(
which
include
an
initial
report
and
semiannual
summaries
of
leak
detection
and
repair)
and
40
CFR
61
subpart
FF
or
40
CFR
63
subpart
H
for
wastewater
operations.
All
records
are
to
be
maintained
at
the
facility
for
at
least
5
years.

!
The
information
collection
is
required
to
ensure
compliance
with
and
enforcement
of
the
petroleum
refineries
NESHAP;

!
EPA
Regions,
and
OECA,
will
use
this
data;

!
This
data
will
be
sent
to
delegated
State
or
Region
and
entered
into
the
AIRS
computer
database;
and
2
!
The
information
collection
will
involve
157
respondents,
469,430
burden
hours
per
year
at
a
total
cost
of
25,647,614
dollars
per
year.

The
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
for
Petroleum
Refineries
(
40
CFR
Part
63,
Subpart
CC)
were
proposed
on
July
15,
1994
and
promulgated
on
August
18,
1995.
These
standards
apply
to
new
and
existing
petroleum
refineries
that
emit
Hazardous
Air
Pollutants
from
the
following
affected
facilities:
process
vents,
storage
vessels,
wastewater
streams
and
equipment
leaks.
This
information
is
being
collected
to
assure
compliance
with
40
CFR
Part
63,
Subpart
CC.

In
general,
all
NESHAP
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
start­
up,
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,
and
are
required
of
all
sources
subject
to
NESHAP.
Older
ICRs
detailed
the
monitoring,
recordkeeping,
and
reporting
requirements
in
this
section.
Now
this
section
only
contains
a
brief
insight
into
the
requirements.
Section
4b
now
contains
this
detail.

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
five
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.

Approximately
153
sources
are
currently
subject
to
the
standard,
and
it
is
estimated
that
no
new
sources
will
become
subject
to
the
standard
in
the
next
three
years.
There
is
one
affected
source
per
refinery
(
respondent).
This
information
was
gathered
from
EPA's
AIRs
data
base
and
the
Department
of
Energy.

2.
Need
for
and
Use
of
the
Collection
2(
a)
Need/
Authority
for
the
Collection
The
EPA
is
charged
under
Section
112
of
the
Clean
Air
Act,
as
Amended,
to
establish
standards
of
performance
for
each
category
or
subcategory
of
major
sources
and
area
sources
of
hazardous
air
pollutants.
These
standards
are
applicable
to
new
or
existing
sources
of
hazardous
air
pollutants
and
shall
require
the
maximum
degree
of
emission
reduction.
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
3
methods;
(
D)
sample
such
emissions
(
in
accordance
with
such
procedures
or
methods,
at
such
locations,
at
such
intervals,
during
such
periods,
and
in
such
manner
as
the
Administrator
shall
prescribe);
(
E)
keep
records
on
control
equipment
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,
HAP
emissions
from
petroleum
refineries
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
NESHAP
were
promulgated
for
this
source
category
at
40
CFR
Part
63,
Subpart
CC.

2(
b)
Practical
Utility/
Users
of
the
Data
The
control
of
emissions
of
HAP
from
refinery
process
units,
process
piping
equipment
components,
and
storage
vessels
requires
not
only
the
installation
of
properly
designed
equipment,
but
also
the
operation
and
maintenance
of
that
equipment.
Emissions
of
HAP
from
refinery
process
units,
process
piping
equipment
components,
and
storage
vessels
are
the
result
of
operation
of
the
affected
facilities.
These
standards
rely
on
the
capture
and
reduction
of
HAP
emissions
by
emission
control
devices
and
leak
detection
and
repair
procedures.
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
1)
pollution
control
devices
are
properly
installed
and
operated;
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.
The
semiannual
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.
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/
61/
63
(
pick
one),
Subpart(
provide).

3(
a)
Nonduplication
If
the
standard
has
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
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
4
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
September
15,
2000,
(
65
FR
55955);
no
comments
were
received.

3(
c)
Consultations
There
was
no
significant
change
in
burden
for
this
ICR.

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
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
The
respondents
of
the
recordkeeping
and
reporting
requirements
are
petroleum
refineries.
The
SIC
code
for
the
respondents
affected
by
the
standards
is
SIC
(
U.
S.
Standard
Industrial
5
Classification)
2911
which
corresponds
to
the
NAICS
(
The
North
American
Industry
Classification
System)
324
for
petroleum
refineries.

Regulation
SIC
Codes
NAICS
Codes
40
CFR
Part
63,
Subpart
63
2911
324
4(
b)
INFORMATION
REQUESTED
This
rule
requires
affected
facilities
to
maintain
all
records,
including
reports
and
notifications
for
at
least
five
years.
This
is
consistent
with
the
General
Provision
to
the
rule.
EPA
believes
that
the
five
year
records
retention
requirement
is
consistent
the
Part
70
permit
program
and
the
five
year
statute
of
limitations
on
which
the
permit
program
is
based.
Also,
the
retention
of
records
for
five
years
would
allow
EPA
to
establish
a
source's
history
and
patterns
of
compliance
for
purposes
of
determining
the
appropriate
level
of
enforcement
action.
Historically,
EPA
has
found
that
the
most
flagrant
violators
frequently
have
violations
extending
beyond
the
five
year
statute
of
limitations.
Therefore,
EPA
would
be
prevented
from
pursuing
the
worst
violators
due
to
the
destruction
or
nonexistence
of
records
if
less
than
five
years
of
records
were
kept.

Summary
of
Information
Collection
Respondents
are
required
to
submit
one­
time
reports
of
start
of
construction,
anticipated
and
actual
start­
up
dates,
and
physical
or
operational
changes
to
existing
facilities.
In
addition,
subpart
CC
would
require
respondents
to
submit
three
types
of
reports:
(
1)
Notification
of
Compliance
Status,
(
2)
Periodic
Reports
and
(
3)
Other
event
triggered
reports.
The
Notification
of
Compliance
Status
is
submitted
to
provide
the
information
necessary
to
demonstrate
that
compliance
has
been
achieved.
The
Periodic
Reports
provide
information
on
monitored
control
device
parameters
when
they
are
outside
of
established
ranges
and
information
on
instances
where
inspections
revealed
problems.
In
addition,
respondents
are
required
to
comply
with
the
recordkeeping
and
reporting
requirements
contained
in
either
40
CFR
61
subpart
VV
or
40
CFR
63
subpart
H
for
equipment
leaks
(
which
include
an
initial
report
and
semiannual
summaries
of
leak
detection
and
repair)
and
40
CFR
61
subpart
FF
or
40
CFR
63
subpart
H
for
wastewater
operations.
All
records
are
to
be
maintained
at
the
facility
for
at
least
5
years.

The
following
types
of
one­
time
reports
are
required
for
petroleum
refineries
affected
by
the
NESHAP.

°
For
new
sources
with
an
initial
start­
up
90
days
after
the
date
of
promulgation
or
later,
the
application
for
approval
of
construction
or
reconstruction
required
by
§
63.5
(
d)
of
40
CFR
63
subpart
A
(
General
Provisions)
shall
be
submitted.
6
°
Notification
of
anticipated
construction
or
reconstruction
of
a
source
subject
to
a
relevant
standard
shall
be
submitted
as
soon
as
practicable
before
commencement
of
construction
or
reconstruction
but
it
need
not
be
sooner
that
90
days
after
the
date
of
promulgation.

°
Notification
of
commencement
of
construction
not
later
that
30
days
after
such
date
(
§
3.9
(
b)(
4)(
iii)
of
subpart
A).

°
Notification
of
anticipated
date
of
initial
start­
up
not
more
than
60
days
nor
less
than
30
days
prior
to
such
date
(
§
63.9(
b)(
4)(
iv)
of
subpart
A).

°
Notification
of
the
actual
date
of
start­
up,
within
15
days
after
such
date
(
§
63.9(
b)(
4)(
v)
of
subpart
A).

°
Notification
of
reconstruction
of
an
existing
facility
not
later
than
30
days
after
the
date
is
commenced
§
63.9(
b)(
4)(
iii)
of
subpart
A).

°
Notification
of
installation
of
a
new
control
device
or
reconstruction
of
an
existing
control
device
as
soon
as
practicable
before
the
installation
or
reconstruction
is
planned
to
commence
(
§
63.5(
b)(
6)
and
§
63.5(
d)(
1)
of
subpart
A).

°
A
Notification
of
Compliance
Status
Report
is
due
within
150
days
of
the
compliance
date.
The
notification
includes
performance
test
results
(
for
those
emission
points
that
require
tests)
and
other
information
to
demonstrate
compliance,
as
well
as
site­
specific
ranges
for
operating
parameters
that
will
be
monitored
(
§
3.652(
e)
of
subpart
CC).

°
For
equipment
leaks,
the
notification
of
compliance
status
is
due
150
days
after
the
compliance
date
and
includes
the
information
specified
in
40
CFR
63
subpart
H
(
§
63.652(
b)
of
subpart
CC
and
§
63.182
of
subpart
H).

°
The
owner
or
operator
of
an
affected
facility
must
notify
the
Administrator
30
days
prior
to
the
date
of
a
performance
test
(
§
63.642(
d)(
2)
of
subpart
CC).

°
An
extension
of
compliance
report
must
be
submitted
if
the
owner
or
operator
cannot
comply
with
the
standard
by
the
designated
date
(
§
63.9(
c)
of
subpart
A).

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

°
Periodic
leak
detection
and
repair
(
LDAR)
data
on
process
equipment.
Frequency
varies
by
equipment
type.
Records
are
to
be
kept
as
specified
in
40
CFR
60
subpart
VV
or
40
CFR
63
subpart
H.
Semiannual
summary
reports
are
to
be
filed
as
specified
in
subpart
VV
or
subpart
H.
7
°
Annual
inspections
of
storage
vessels
with
floating
roofs
are
to
be
made
as
required
by
§
63.646
of
subpart
CC
and
§
63.120
of
subpart
G.
Records
are
to
be
kept
and
reports
of
inspections
that
detected
failures
filed
in
periodic
reports
as
specified
in
§
63.652(
f)
and
(
h)
of
subpart
CC.

°
A
record
of
parameter
monitoring
data
for
certain
process
vent
control
devices
is
to
be
kept
daily,
and
a
report
of
exceedances
submitted
semiannually
pursuant
to
§
63.652(
f)
and(
h)
of
subpart
CC.

°
Records
required
by
this
NESHAP
must
be
retained
by
the
owner
or
operator
for
5
years
(
§
63.652(
h)
of
subpart
CC).

(
i)
Data
Items
All
data
in
this
ICR
that
is
recorded
and/
or
reported
is
required
by
40
CFR
Part
63,
Subpart
CC
­
National
Emissions
Standards
for
Hazardous
Air
Pollutants
from
Petroleum
Refineries.

A
source
must
make
the
following
reports:

Reports
for
40
CFR
Part
63,
Subpart
CC
Construction/
reconstruction
60.7(
a)(
1),
63.5
Construction
or
modification
application
61.07
Initial
notifications
63.9(
b)

Anticipated
start­
up
60.7(
a)(
2),
61.09(
a)(
1)

Actual
start­
up
60.7(
a)(
3),
61.09(
a)(
2)

Initial
performance
test
results
60.8
(
a),
61.13(
f)
,
63.10(
d)(
2)

Initial
performance
test
60.8(
d),
61.13(
c),
63.7(
b),
63.9(
e)

Rescheduled
initial
performance
test
63.7(
b)(
2)

Demonstration
of
continuous
monitoring
system
60.7(
a)(
5),
61.
X
,
63.9(
g)

Compliance
status
63.9(
h)
8
Reports
for
40
CFR
Part
63,
Subpart
CC
Physical
or
operational
change
60.7(
a)(
4),
61.15
,
63.
X
Opacity
or
visible
emissions
63.10(
d)(
3)

Periodic
start­
up,
shutdown,
malfunction
reports
63.10(
d)(
5)(
I)

Source
status
report
61.10(
a)
,
63.
X
Reporting
for
emissions
averaging
63.653,
63.654(
f)(
5)
and
(
g)(
8)

Reporting
for
emissions
averaging
for
equipment
leak
standards
63.654(
d)(
1)
and
(
d)(
3)

Reporting
Requirements
specific
to
this
standard
63.654
A
source
must
maintain
the
following
records:

Recordkeeping
for
40
CFR
Part
63,
Subpart
CC
Start­
ups,
shutdowns,
malfunctions,
periods
where
the
continuous
monitoring
system
is
inoperative
(
60.7(
b),
61.
X
,
63.10(
b)(
2)

Emission
test
results
and
other
data
needed
to
determine
emissions
61.13(
g)

All
reports
and
notifications
63.10(
b)

Record
of
applicability
63.10(
b)(
3)

Records
for
sources
with
continuous
monitoring
systems
63.10(
3)

Records
are
required
to
be
retained
for
5
of
Years.
All
MACT
standards
require
five
years
of
record
retention.
The
first
two
years
of
records
must
be
retained
at
the
facility.
60.
X,
61.
X,
63.
X
Recordkeeping
requirements
specific
to
this
standard
63.654
(
ii.)
Respondent
Activities
Respondent
Activities
1.
Read
Rule
and
Instructions
9
Respondent
Activities
a.
Applicability/
General
Recordkeeping
and
Reporting
b.
Storage
Vessels
c.
Equipment
Leaks
d.
Process
Vents
Plan
Activities
a.
Applicability/
General
Recordkeeping
and
Reporting
b.
Storage
Vessels
­
8
hours
per
vessel
initially,
1
hour
per
tank
annually
c.
Equipment
Leaks
­
6
hours
per
unit
initially,
1
hour
per
unit
annually
d.
Process
Vents
­
2
hours
per
vent
initially,
1
hour
per
vent
annually
Training
a.
Storage
Vessels
­
1
hour
per
vessel
initially
b.
Equipment
Leaks
­
1
hour
per
unit
initially,
½
hour
per
unit
annually
c.
Process
Vents
­
1
hour
per
vent
initially,
1
hour
annually
for
vents
to
control
devices
4.
Create,
Test,
Research
and
Develop
a.
Storage
vessels
­
perform
design
analysis
and
establish
operating
parameters
for
one
closed
vent
system
b.
Equipment
leaks
­
2
hours
per
process
unit
c.
Process
vents
­
perform
initial
performance
test
for
two
process
vent
control
devices
d.
Process
vents
­
repeat
performance
test
for
one
process
vent
control
device
5.
Gather
Information,
Monitor,
and
Inspect
a.
Storage
vessels
­
3
hours
per
inspection
per
vessel
b.
Equipment
leaksb
c.
Process
vents
­
1
hour
per
monitored
parameter
per
month
6.
Process,
Compile
and
Review
Information
a.
Storage
vessels
­
4
hours
per
vessel
initially
and
1
½
hours
per
vessel
each
reporting
period
b.
Equipment
leaks
­
24
hours
per
unit
initially
and
2
hours
per
unit
per
month
c.
Process
vents
­
12
hours
per
control
device
initially
and
5
minutes
per
day
per
parameter
monitored,
350
days
of
operation
per
year
7.
Complete
Reports
10
Respondent
Activities
a.
Notification
of
Compliance
Status
i.
Storage
vessels
­
1
hour
per
Group
1
vessel,
16
hours
for
Group
2
vessels
ii.
Equipment
leaks
­
4
hours
per
unit
iii.
Process
vents
­
1
hour
per
Group
1
vent,
16
hours
for
Group
2
vents
b.
Other
Reports
i.
Notification
of
storage
vessel
inspection
­
1
hour
per
vessel
ii.
Notification
of
process
vent
control
device
test
­
4
hours
per
notification,
two
test
dates
c.
Semi­
Annual
Reports
i.
Overall
ii.
Storage
vessels
­
1
hour
per
vessel,
3
hours
per
seal
gap
measurement
failure
iii.
Equipment
leaks
­
3
hours
per
unit
iv.
Process
vents
­
1.5
hours
per
monitored
control
device
8.
Record
and
Disclose
Information
a.
Storage
vessels
­
2
hours
per
vessel
initially
and
per
reporting
period
b.
Equipment
leaks
­
address
enforcement
actions,
75
hours
per
unit
initially
and
annually
c.
Process
vents
­
1
hour
per
monitored
control
device
per
reporting
period
9.
Store/
File
a.
Storage
vessels
­
2
hours
per
vessel
initially
and
per
reporting
period
b.
Equipment
leaks
­
75
hours
per
process
unit
initially
and
annually
c.
Process
vents
­
2
hours
per
vent
initially
and
annually
This
collection
of
information
does
not
require
the
use
of
automated
collection
techniques
due
to
the
relatively
small
number
of
respondents
(
157)
affected.

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
1.
REPORT
REVIEWS
2.
INSPECTIONS
a.
Perform
tests
11
Agency
Activities
b.
Annual
inspection
of
facility
records
3.
LITIGATION
4.
TRAVEL
5(
b)
Collection
Methodology
and
Management
The
reporting
requirements
for
facilities
subject
to
the
NESHAP
consist
of
certain
one­
time
reports
and
a
minimal
amount
of
periodic
recordkeeping
and
reporting.
Periodic
monitoring
and
corresponding
records
of
the
process
piping
equipment
components
are
required.
Storage
vessels
require
annual
inspections
and
associated
records.
Certain
process
vent
control
devices
require
continuous
parameter
monitoring.
Results
of
monitoring
and
inspections
are
submitted
in
semiannual
reports.

The
information
will
be
used
by
agency
enforcement
personnel
to:
(
1)
identify
new,
modified,
and
reconstructed
sources
subject
to
the
standards;
(
2)
identify
the
control
methodology
being
applied;
(
3)
ensure
that
emission
control
devices
are
being
properly
operated
and
maintained;
and
(
4)
ensure
that
emissions
from
process
piping
equipment
components
and
storage
vessels
are
minimized
and
defects
repaired
on
a
timely
basis.

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

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
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
five
years.

5(
c)
Small
Entity
Flexibility
The
minority
of
affected
facilities
are
small
business
(
often
employing
less
than
ten
people).

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
12
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
Table
2:
Industry
Burden.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
Table
1
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.
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.

6a.
Burden
Associated
With
Emissions
Averaging
In
the
original
burden
estimate,
it
was
assumed
that
50
percent
of
refineries
complying
with
the
petroleum
refineries
NESHAP
would
make
use
of
the
emissions
averaging
provisions.
Emissions
averaging
allows
regulated
facilities
to
control
emission
points
to
levels
less
than
required
by
the
rule
if
other
emission
points
are
controlled
to
levels
greater
than
required
by
the
rule.
Additional
recordkeeping
and
reporting
is
required
of
refineries
using
emissions
averaging
in
order
to
ensure
that
the
net
decrease
in
emissions
achieved
is
greater
than
the
decrease
that
would
have
been
achieved
without
emissions
averaging.

Currently,
it
is
expected
none
of
the
refineries
subject
to
the
NESHAP
will
use
emissions
averaging.
The
date
by
which
facilities
are
required
to
submit
an
implementation
plan
if
using
emissions
averaging
has
passed
and
no
implementation
plans
have
been
received.
Consequently,
no
hours
are
included
in
table
1
for
recordkeeping
and
reporting
activities
associated
with
emissions
averaging.

6b.
Burden
Associated
With
Information
Collection
Activities
Performed
By
Outside
Parties
The
original
burden
estimate
included
hours
in
the
respondent
burden
for
activities
that
would
most
likely
be
performed
by
an
outside
party.
Current
guidance
requires
that
such
activities
be
separated
from
the
burden
hours.
Activities
that
most
likely
would
be
performed
by
a
contractor
13
include
performance
tests
that
are
required
to
demonstrate
the
efficiency
of
some
control
devices.
The
performance
tests
are
conducted
prior
to
the
compliance
date.

The
original
burden
estimate
assumed
that
an
average
of
two
process
vent
control
devices
will
require
a
performance
test,
and
that
one
of
the
control
devices
will
fail
the
first
test
and
require
a
second
test.

In
order
to
make
the
estimate
consistent
with
current
guidance,
the
majority
of
hours
associated
with
performance
tests
are
not
included
in
the
burden
estimate.
A
relatively
small
number
of
hours
is
included
to
account
for
the
time
spent
by
refinery
personnel
arranging
and
supervising
the
performance
tests.

6(
c)
Estimating
Respondent
Burden
The
average
annual
burden
to
industry
over
the
next
three
years
from
these
recordkeeping
and
reporting
requirements
is
estimated
at
469,430
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
NESHAP
program,
the
previously
approved
ICR,
and
any
comments
received.

6(
d)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
This
ICR
uses
the
following
labor
rates:
$
78.54
per
hour
for
Executive,
Administrative,
and
Managerial,
$
55.34
per
hour
for
Technical,
and
$
35.64
per
hour
for
Clerical
are
used
in
this
ICR.
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
increase
by
110%
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.

Managerial
$
78.54
($
37.40
+
110%)
Technical
$
55.34
($
26.35
+
110%)
Clerical
$
35.64
($
16.97
+
110%))

(
ii)
Estimating
Capital/
Startup
and
Operation
and
Maintenance
Costs
Since
this
rule
does
not
require
any
continuous
emissions
monitoring
or
electronic
data
submittal,
total
capital
costs
are
expected
to
be
insignificant.
Continuous
monitoring
requirements
are
for
parametric
monitoring
and
these
systems
are
already
in
place,
therefor,
no
new
equipment
would
be
required
by
the
recordkeeping
and
reporting
requirements.

(
iii)
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
14
There
are
expected
to
be
start­
up
costs
associated
with
initial
performance
tests.
It
is
assumed
that
all
refineries
will
contract
a
testing
company
to
provide
sampling
and
analytical
services
required
to
demonstrate
that
control
devices
achieve
the
required
emission
reduction.
It
is
estimated
that
three
tests
will
be
performed
for
process
vent
control
devices
at
all
refineries.

Based
on
EPA's
experience,
the
required
services
cost
approximately
$
4,280
for
the
first
test
performed
at
a
facility
and
$
1,800
for
each
additional
test
performed
during
the
same
time
period.
It
is
assumed
that
all
initial
tests
would
be
performed
over
one
time
period
and
all
required
repeat
tests
would
be
performed
over
a
single,
subsequent
time
period.
The
estimated
cost
per
refinery
is
$
10,360:

initial
tests
(
2):
$
4,280
+
$
1,800
+
repeat
test
(
1):
$
4,280
$
10,360
The
total
industry
cost
is
therefore
$
1,626,520:

($
10,360
*
157
refineries)
=
$
1,626,520
Over
three
years,
the
total
startup
costs
average
$
542,173
per
year.

6e.
Total
Operation
and
Maintenance
and
Purchase
of
Service
Cost
Since
this
rule
does
not
require
any
additional
monitoring
equipment,
operation,
maintenance,
and
purchase
of
service
costs
are
expected
to
be
insignificant.

6(
f)
Estimating
Agency
Burden
and
Cost
The
only
costs
to
the
Agency
are
user
costs
associated
with
analysis
of
the
reported
information.
Publication
and
distribution
of
the
information
are
part
of
the
AIRS
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
$
223,398
[
see
Table
2
in
Attachment
A].
This
cost
is
based
on
the
average
hourly
labor
rate
at
a
GS­
12,
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
2.
15
6(
g)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Respondent
Universe
Regulation
Citation
(
A)
No.
of
New
Sources/
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
63.640
0
4
157
8
1,256
The
number
of
total
respondents
is
157.
This
number
is
the
sum
of
Column
A
and
Column
C
of
the
Respondent
Universe
table.
It
is
shown
on
the
OMB
83­
I
form
in
block
13
a.
This
is
the
number
of
existing
sources
plus
the
number
of
new
sources
averaged
over
the
three
year
period.

The
"
Total
annual
responses"
is
1,256.
This
number
is
in
column
E
of
the
Respondent
Universe
table.
It
is
shown
on
the
OMB
83­
I
form
in
block
13
b.
The
total
annual
labor
costs
are
25,647,614
.
This
number
is
not
shown
on
the
OMB
83­
I
form
in
block
13c,
only
the
burden
hours
are
reflected
in
block
13c.
Details
upon
which
this
estimate
is
based
appear
in
Table
1.
Annual
Respondent
Burden
and
Cost.

The
total
annual
capital
and
O&
M
costs
to
the
regulated
entity
are
542,173.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
14
c.
These
costs
are
detailed
in
section
6
d
(
iii)
Capital/
Start­
up
vs.
Operating
and
Maintenance
(
O&
M)
Costs.

6(
h)
Bottom
Line
Burden
Hours
Burden
Hours
And
Cost
Tables
The
bottom
line
burden
hours
and
cost
tables
for
the
respondents
and
the
Agency
are
attached).

6(
i)
Reasons
for
Change
in
Burden
The
increase
in
the
cost
burden
from
the
most
recently
approved
ICR
is
due
to
an
increase
in
the
labor
rates.
The
decrease
in
the
burden
hours
(
23,570
Adjustment)
is
because
the
number
of
respondents
went
down
from
the
previous
ICR
submittal
by
8
facilities.

6(
j)
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;
16
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
Ms.
Susan
Auby,
Collection
Strategies
Division
(
Mail
Code
2822),
Office
of
Environmental
Information,
United
States
Environmental
Protection
Agency,
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,
DC
20503,
Attention:
Desk
Officer
for
EPA.
Include
the
EPA
ICR
number
1692.04,
and
OMB
Control
Number
2060­
0340
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
Attachment
A
ICR
Burden
Tables
TABLE
1.
ANNUAL
RESPONDENT
BURDEN
AND
COST
OF
RECORDKEEPING
AND
REPORTING
REQUIREMENTS
OF
THE
PETROLEUM
REFINERIES
NESHAP
Burden
Item
(
A)
Annualized
Initial
Hoursa
(
B)

Hours
Per
Periodic
Occurrence
(
C)
Periodic
Occurrences
Per
Year
(
D)
Technical
Hours
per
Respondent
Per
Year
(
D=
A+
BxC)
(
E)
Technical
Hours
Per
Year
(
Dx157)
(
F)
Management
Hours
Per
Year
(
Ex0.05)
(
G)
Clerical
Hours
Per
Year
(
Ex0.1)
(
H)

Total
Cost
(
Ex55.34+
Fx78.54+
Gx35.

64)

1.
Read
Rule
and
Instructions
e.
Applicability/
General
Recordkeeping
and
Reporting
2
4
2
10
f.
Storage
Vessels
2
1
2
4
g.
Equipment
Leaks
2
2
2
6
h.
Process
Vents
2
2
2
6
Subtotal
26
4,082
204
408
256,461
2.
Plan
Activities
a.
Applicability/

General
Recordkeeping
and
Reporting
5
3
2
11
b.
Storage
Vessels
­
8
hours
per
vessel
initially,
1
hour
per
tank
annually
7
9
1
16
c.
Equipment
Leaks
­
6
hours
per
unit
initially,
1
hour
per
unit
annually
7
11
1
18
d.
Process
Vents
­
2
hours
per
vent
initially,
1
hour
per
vent
annually
2
9
1
11
Subtotal
56
8,792
440
879
552,435
3.
Training
a.
Storage
Vessels
­
1
hour
per
vessel
initially
1
1
b.
Equipment
Leaks
­
1
hour
per
unit
initially,
½
hour
per
unit
annually
1
5.5
1
6.5
c.
Process
Vents
­
1
hour
per
vent
initially,
1
hour
annually
for
vents
to
control
devices
1
4
1
5
Subtotal
12.5
1,963
98
196
123,314
kam\
C:\
dmautop\
temp\
dwcgi­
25036­
1054226403­
350250000.
wpd
19
TABLE
1.
Continued
Burden
Item
(
A)
Annualized
Initial
Hoursa
(
B)

Hours
Per
Periodic
Occurrence
(
C)
Periodic
Occurrences
Per
Year
(
D)
Technical
Hours
per
Respondent
Per
Year
(
D=
A+
BxC)
(
E)
Technical
Hours
Per
Year
(
Dx157)
(
F)
Management
Hours
Per
Year
(
Ex0.05)
(
G)
Clerical
Hours
Per
Year
(
Ex0.1)
(
H)

Total
Cost
(
Ex55.34+
Fx78.54+
Gx35.

64)

4.
Create,
Test,
Research
and
Develop
a.
Storage
vessels
­
perform
design
analysis
and
establish
operating
parameters
for
one
closed
vent
system
8
8
b.
Equipment
leaks
­
2
hours
per
process
unit
2
2
c.
Process
vents
­
perform
initial
performance
test
for
two
process
vent
control
devices
2
2
d.
Process
vents
­
repeat
performance
test
for
one
process
vent
control
device
1
1
Subtotal
13
2,041
102
204
128,231
5.
Gather
Information,
Monitor,
and
Inspect
a.
Storage
vessels
­
3
hours
per
inspection
per
vessel
27
1
27
b.
Equipment
leaksb
c.
Process
vents
­
1
hour
per
monitored
parameter
per
month
2
12
24
Subtotal
51
8,007
400
801
503,071
6.
Process,
Compile
and
Review
Information
a.
Storage
vessels
­
4
hours
per
vessel
initially
and
1
½
hours
per
vessel
each
reporting
period
4
13.5
2
31
b.
Equipment
leaks
­
24
hours
per
unit
initially
and
2
hours
per
unit
per
month
26
22
12
290
c.
Process
vents
­
12
hours
per
control
device
initially
and
5
minutes
per
day
per
parameter
monitored,
350
days
of
operation
per
year
2
0.17
350
61.5
Subtotal
382.5
60,053
3,003
6,005
3,773,207
kam\
C:\
dmautop\
temp\
dwcgi­
25036­
1054226403­
350250000.
wpd
20
TABLE
1.
Continued
Burden
Item
(
A)
Annualized
Initial
Hoursa
(
B)

Hours
Per
Periodic
Occurrence
(
C)
Periodic
Occurrences
Per
Year
(
D)
Technical
Hours
per
Respondent
Per
Year
(
D=
A+
BxC)
(
E)
Technical
Hours
Per
Year
(
Dx157)
(
F)
Management
Hours
Per
Year
(
Ex0.05)
(
G)
Clerical
Hours
Per
Year
(
Ex0.1)
(
H)

Total
Cost
(
Ex55.34+
Fx78.54+
Gx35.

64)

7.
Complete
Reports
a.
Notification
of
Compliance
Status
i.
Storage
vessels
­
1
hour
per
Group
1
vessel,
16
hours
for
Group
2
vessels
3
3
ii.
Equipment
leaks
­
4
hours
per
unit
4
4
iii.
Process
vents
­
1
hour
per
Group
1
vent,
16
hours
for
Group
2
vents
3
3
b.
Other
Reports
i.
Notification
of
storage
vessel
inspection
­
1
hour
per
vessel
1
1
ii.
Notification
of
process
vent
control
device
test
­
4
hours
per
notification,

two
test
dates
1
1
c.
Semi­
Annual
Reports
i.
Overall
18
2
36
ii.
Storage
vessels
­
1
hour
per
vessel,
3
hours
per
seal
gap
measurement
failure
12
2
24
iii.
Equipment
leaks
­
3
hours
per
unit
33
2
66
iv.
Process
vents
­
1.5
hours
per
monitored
control
device
3
2
6
Subtotal
144
22,608
1,130
2,261
1,420,459
8.
Record
and
Disclose
Information
a.
Storage
vessels
­
2
hours
per
vessel
initially
and
per
reporting
period
2
18
2
38
b.
Equipment
leaks
­
address
enforcement
actions,
75
hours
per
unit
initially
and
annually
82.5
825
1
907.5
c.
Process
vents
­
1
hour
per
monitored
control
device
per
reporting
period
2
2
4
Subtotal
949.5
149,072
7,454
14,907
9,366,366
kam\
C:\
dmautop\
temp\
dwcgi­
25036­
1054226403­
350250000.
wpd
21
TABLE
1.
Continued
Burden
Item
(
A)
Annualize
d
Initial
Hoursa
(
B)

Hours
Per
Periodic
Occurren
ce
(
C)
Periodic
Occurrence
s
Per
Year
(
D)
Technical
Hours
per
Responde
nt
Per
Year
(
D=
A+
Bx
C)
(
E)
Technic
al
Hours
Per
Year
(
Dx157)
(
F)
Managem
ent
Hours
Per
Year
(
Ex0.05)
(
G)
Cleric
al
Hours
Per
Year
(
Ex0.1
)
(
H)

Total
Cost
(
Ex55.34+
Fx78.54+

Gx35.64)

9.
Store/
File
a.
Storage
vessels
­
2
hours
per
vessel
initially
and
per
reporting
period
2
18
2
38
b.
Equipment
leaks
­
75
hours
per
process
unit
initially
and
annually
82.5
825
1
907.5
c.
Process
vents
­
2
hours
per
vent
initially
and
annually
2
18
1
20
Subtotal
965.5
151,548
7,579
15,158
9,524,145
TOTAL
2,600
408,200
20,410
40,820
25,647,614
aInitial,
one­
time
burden
hours
are
annualized
over
10
years.
It
is
assumed
that
these
initial
activities
will
not
have
to
be
repeated
over
the
life
of
the
equipment.

bThis
estimate
does
not
include
the
monitoring
of
equipment
leak
components.
The
cost
for
monitoring
equipment
leak
components
is
included
as
part
of
the
cost
of
the
leak
detection
and
repair
program,
which
is
a
requirement
of
the
regulation.

Additional
Assumptions
.
Nine
storage
vessels
per
refinery
require
control.

.
Eleven
units
per
refinery
are
subject
to
equipment
leak
provisions.

.
Each
refinery
has
nine
process
vents.
Five
are
routed
to
fuel
gas
system,
four
are
routed
to
a
control
device,
and
two
control
devices
require
testing
and
monitoring.

.
157
Refineries
are
subject
to
the
petroleum
refineries
NESHAP.

.
Managerial
hours
are
assumed
to
be
5%
of
technical
hours.

.
Clerical
hours
are
assumed
to
be
10%
of
technical
hours.

.
Total
cost
is
based
on
the
following
hourly
wage
rates:
technical
­
$
55.34,
managerial
­
$
78.54,
clerical
­
$
35.64.
TABLE
2.
ANNUAL
AGENCY
BURDEN
AND
COST
TO
IMPLEMENT
THE
PETROLEUM
REFINERIES
NESHAP
Activity
Hours
per
Occurrence
(
A)
Number
of
Occurrences
(
B)
Person­
hours
(
C­
AxB)
Annual
Cost,

$

(
D­
Cx$
36.98)

REPORT
REVIEWS
Notification
of
compliance
status
10
157
1,570
58,059
Semiannual
equipment
leak
reportsa
10
157
1,570
58,059
Semiannual
parameter
exceedance
reportsb
4
157
628
23,223
Annual
storage
tank
inspection
failuresa
4
79
316
11,686
Notification
of
constr./
reconstr.
c
1
79
79
2,921
Notification
of
anticipated
start­
upc
1
79
79
2,921
Notification
of
actual
start­
upc
1
79
79
2,921
Notification
of
performance
test
1
19
19
703
INSPECTIONS
Perform
tests
8
10
80
2,958
Annual
inspection
of
facility
records
8
157
1,256
46,447
LITIGATION
1,000
0d
0
0
TOTAL
BURDEN
AND
COST
(
Salary)
5,676
209,898
Travele
13,500
TOTAL
ANNUAL
COST
223,398
aAssumes
that
50%
of
sources
affected
by
the
rule
are
already
submitting
reports
to
comply
with
existing
regulations.

bAssumes
parameter
monitoring
one
vent
per
refinery,
one
exceedance
per
year.

cApplies
only
to
process
vents
and
assumes
one
vent
per
source.
Notifications
related
to
construction
of
new
sources
or
reconstruction
of
existing
sources
are
accounted
for
in
existing
NSPS
and
NESHAP
regulations
for
equipment
leaks,
wastewater
and
storage
tanks
that
apply
to
petroleum
refineries.

Assumes
that
50%
of
sources
are
affected
by
the
requirement
per
year.

dNo
litigation
has
occurred
as
a
result
of
the
promulgation
of
the
petroleum
refineries
NESHAP.

eTravel
cost
based
on
30
trips
for
1
person
at
$
400
per
round
trip
and
$
50
per
diem.
