1
SF­
83
SUPPORTING
STATEMENT
U.
S.
ENVIRONMENTAL
PROTECTION
AGENCY
National
Emission
Standards
for
Hazardous
Air
Pollutants,
Benzene
Emissions
from
Benzene
Storage
Vessels,
and
Coke
By­
Product
Recovery
Plants
Section
A
(
Subpart
L)

1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
ICR
for
NESHAP,
SUBPART
L
­
Benzene
Emissions
from
Coke
By­
Product
Recovery
Plants
1(
b)
Short
Characterization/
Abstract
Subpart
L
was
revised
on
September
19,
1991
to
allow
for
the
use
of
carbon
adsorbers
and
vapor
incinerators
as
alternative
means
of
complying
with
the
standards
for
process
vessels,
storage
tanks
and
tar­
intercepting
sumps.
The
use
of
carbon
adsorbers
and
vapors
incinerators
instead
of
gas
blanketing,
the
control
technology
on
which
the
standards
were
based,
is
optional.
The
provisions
include
record
keeping
and
reporting
requirements
specific
to
these
alternative
control
devices.
An
information
collection
request
(
ICR
number
1080.07)
was
developed
for
that
revision
and
is
consolidated
into
this
ICR
with
this
review.

Approximately
36
sources
are
currently
subject
to
the
standard,
and
it
is
estimated
that
no
additional
sources
will
become
subject
to
the
standard
in
the
next
three
years.
The
cost
of
this
ICR
will
be
$
311,652
dollars.

Respondents
are
all
owners
or
operators
of
furnace
and
foundry
coke
by­
product
recovery
plants.
Approximately
36
sources
are
currently
subject
to
the
standard,
and
it
is
estimated
that
no
additional
sources
will
become
subject
to
the
standard
in
the
next
three
years.
Benzene
is
the
pollutant
regulated
under
Subpart
L.

The
control
requirements
for
coke
by­
product
recovery
plants
require
that
organic
vapors
be
recovered
and
routed
via
closed­
vent
system
(
no
detectable
emissions)
to
a
control
device
that
achieves
a
95
percent
or
greater
destruction
efficiency.
The
affected
equipment
must
not
exceed
a
specified
level
of
equipment
leaks,
either
through
a
concentration
standard,
or
in
the
case
of
valves,
a
percent
of
total
valves
standard
is
optional.
The
control
of
emissions
of
benzene
from
recovery
plants
requires
not
only
the
installation
of
properly
designed
equipment,
but
also
the
2
operation
and
maintenance
of
that
equipment.
Emissions
of
benzene
from
recovery
plants
covered
by
this
regulation
are
the
result
of
leaking
equipment.
Therefore,
coke
by­
product
recovery
plants
subject
to
this
regulation
shall
comply
with
the
requirements
of
Subpart
V,
National
Emission
Standard
for
Equipment
Leaks
(
Fugitive
Emission
Sources),
as
specified
in
§
61.137.

Owners
or
operators
of
the
affected
facilities
described
must
make
the
following
one­
time­
only
reports:
notification
of
construction
or
modification;
notification
of
the
anticipated
and
actual
dates
of
startup;
initial
compliance
reports,
notification
of
emission
tests,
report
following
an
emission
test,
notification
of
a
monitoring
system
performance
test.

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
required,
in
general,
of
all
sources
subject
to
any
NESHAP.

Reporting
requirements
specific
to
benzene
coke
by­
product
recovery
plants,
Subpart
L,
include
a
semiannual
report
by
affected
facilities.
The
semiannual
reports
include
results
of
leak
monitoring
and
performance
tests.
Respondents
also
are
required
to
submit
semiannual
reports
of
measurements
for
sources
subject
to
a
no
detectable
emissions
limit
and
semiannual
reports
summarizing
the
results
of
the
leak
detection
and
repair
programs
implemented
at
the
plant.
One
report
would
incorporate
information
for
both
process
equipment
and
fugitive
sources.
These
reports
would
include
information
such
as
number
of
leaks
that
occurred,
the
number
that
could
not
be
repaired,
the
general
reasons
for
unsuccessful
or
delay
of
repair,
and
the
results
of
performance
tests
conducted
during
the
reporting
period.

Monitoring,
record
keeping
and
reporting
requirements
specific
to
benzene
coke
by­
product
recovery
plants
for
leak
detection
and
repair
of
fugitive
emission
sources
are
those
provisions
specified
under
40
CFR
61,
NESHAP
Subpart
V.
The
Subpart
V
regulations
for
equipment
leaks
were
approved
by
the
Office
of
Management
and
Budget
(
OMB)
under
control
number
2060­
0068.
The
only
difference
in
the
equipment
leak
requirements
of
Subpart
V
and
this
regulation
relates
to
exhausters.
Exhausters
are
subject
to
quarterly
monitoring
requirements.
However,
quarterly
monitoring
is
not
required
if
the
exhauster
is
equipped
with
a
seal
system
that
has
a
barrier
fluid,
the
exhauster
seal
is
loaded
and
vented
to
a
control
device,
or
a
leakless
exhauster
is
used.
Exhausters
are
subject
to
the
same
record
keeping
and
reporting
provisions
as
other
equipment
subject
to
Subpart
V.

The
added
control
amendment
to
the
coke­
by­
product
plant
benzene
NESHAP
is
based
on
a
settlement
agreement
pursuant
to
a
petition
to
review
the
benzene
NESHAP
by
the
American
Coke
and
Coal
Chemicals
Institute
(
ACCCI).
The
record
keeping
and
reporting
requirements
contained
in
this
rule
are
consistent
with
those
described
in
the
agreement.
3
The
owner
or
operator
choosing
to
use
one
of
the
alternative
control
technologies
(
i.
e.,
a
carbon
adsorber
or
a
vapor
incinerator)
would
be
required
to
record
for
the
life
of
the
control
device,
the
design
of
the
control
device,
the
sources
which
it
is
intended
to
control,
and
a
plan
for
the
operation,
maintenance
and
action
needed
to
correct
problems.
Such
a
record
would
assist
the
owner
or
operator
to
operate
the
device
properly
throughout
its
life
and
would
also
assist
the
enforcement
personnel
in
determining,
when
reviewing
records
that
indicate
problems
with
the
control
device,
whether
the
device
had
been
properly
maintained
and
appropriate
corrective
action
had
been
taken.
The
owner
or
operator
would
be
required
to
record
the
results
of
each
test
for
determining
compliance
with
the
standard.
Also
required
to
be
recorded,
would
be
any
data
that
provide
reference
values
for
parameters
that
are
important
to
monitoring,
such
as
temperature
of
the
firebox
in
a
vapor
incinerator
and
the
benzene
concentration
at
the
inlet
to
a
carbon
adsorber.
Some
of
these
data
are
gathered
during
the
compliance
test,
others
separately
(
e.
g.,
the
demonstrated
bed
life
of
a
carbon
adsorber).

These
records
would
be
required
to
be
kept
for
at
least
two
years,
or
until
the
next
compliance
test
(
or
time
that
the
parameter
reference
value
is
determined),
whichever
is
longer.
Finally,
the
results
of
monitoring
the
control
device
would
be
required
to
be
recorded
for
at
least
2
years.
The
records
would
include
any
periods
when
the
boundaries
established
for
the
monitored
parameters
were
exceeded
and
the
action
taken
to
correct
the
problem
that
led
to
the
exceedance.

The
alternative
control
options
require
reporting
in
addition
to
record
keeping.
The
General
Provisions
require
reporting
of
compliance
tests.
This
would
be
submitted
each
time
a
compliance
test
is
performed.
The
rule
requires
compliance
tests
to
be
done
initially
and
at
the
request
of
EPA
(
not
at
predetermined
intervals).
In
addition,
the
rule
requires
reporting
of
exceedances
of
the
monitored
parameters,
with
a
brief
description
of
the
corrective
action
taken.
Included
would
be
exceedances
of
the
operating
requirements
such
as
if
the
source
were
not
vented
to
a
fresh
carbon
bed
before
the
maximum
concentration
point
was
exceeded
on
the
spent
bed.
The
reports
are
required
quarterly.
When
semiannual
reports
under
Subpart
L
are
due,
the
information
for
the
quarterly
report
should
be
submitted
as
part
of
the
semiannual
report.
If
there
were
no
exceedances
during
a
quarter
in
which
no
semiannual
report
was
due,
reporting
for
that
quarter
could
be
skipped
and
a
notation
to
that
effect
included
in
the
next
report.
The
reason
that
quarterly
reports
are
required
for
these
control
devices
is
because
the
monitoring
is
generally
continuous
and
therefore
provides
a
continuous
record
of
problems
with
operation
and
maintenance
of
the
device.
Because
of
the
hazardous
nature
of
benzene,
it
is
important
that
enforcement
personnel
are
alerted
to
plants
that
are
having
problems
with
their
control
device
and
are
potentially
in
violation
of
the
standards.
The
enforcement
personnel
can
then
move
quickly
to
make
sure
the
problem
area
is
corrected.

Any
owner
or
operator
subject
to
the
provisions
of
this
part
shall
maintain
an
up­
to­
date
file
of
monitoring
and
recordings,
and
retain
them
for
at
least
two
years
following.
Records
of
equipment
and
process
design
are
kept
permanently.
4
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
or
methods
(
in
accordance
with
such
methods
at
such
locations,
at
such
intervals,
and
in
such
manner
as
the
Administrator
shall
prescribe),
(
D)
sample
such
emissions,
(
E)
keep
records
on
control
equipment
parameters,
production
variables
or
other
indirect
data
when
direct
monitoring
of
emissions
is
impractical,
(
F)
submit
compliance
certifications,
and
(
G)
provide
such
other
information
as
he
may
reasonably
require.

In
the
Administrator's
judgment,
benzene
emissions
from
coke
by­
product
recovery
plants
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
NESHAPs
were
promulgated
for
this
source
category
at
40
CFR
Part
61
Subpart
L
.

2(
b)
PRACTICAL
UTILITY/
USERS
OF
THE
DATA
The
control
of
emissions
of
benzene
from
coke
by­
product
recovery
plants
requires
not
only
the
installation
of
properly
designed
equipment,
but
also
the
operation
and
maintenance
of
that
equipment.
Emissions
of
benzene
from
coke
by­
product
recovery
plants
are
the
result
of
operation
of
tar
decanters,
tar
storage
tanks,
tar­
intercepting
sumps,
flushing
liquor
circulation
tanks,
light­
oil
sumps,
light­
oil
condensers,
light­
oil
decanters,
wash­
oil
decanters,
wash­
oil
circulation
tanks,
naphthalene
processing,
final
coolers,
final
cooling
towers,
and
equipment
intended
to
operate
at
benzene
service
including
pumps:
valves,
exhausters,
pressure
relief
devices,
sampling
connection
systems,
open­
ended
valves
or
lines,
flanges
or
other
connectors,
and
control
devices
or
systems
require
by
40
CFR
§
61.135.
These
standards
rely
on
the
capture
of
benzene
emissions
by
installing
closed
systems,
barrier
fluid
degassing
systems,
closed­
vent
system
to
a
control
device,
closed­
purge
systems
to
a
control
device,
seal
systems,
and
by
monitoring
equipments
to
repair
leaks
as
soon
as
practicable,
as
specified
in
Subpart
V.
5
3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
3(
a)
Nonduplication
The
record
keeping
and
reporting
requested
is
required
under
40
CFR
Part
61
Subpart
L.
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
a
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
July
12,
1999
(
64
FR
37530).

3(
c)
Consultations
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.

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
record
keeping
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
record
keeping
requirements
contained
in
40
CFR
Part
61
Subpart
L
or
otherwise
pertinent
to
this
request
violates
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).
6
3(
g)
Sensitive
Questions
None
of
the
reporting
or
record
keeping
requirements
contained
in
(
40
CFR
Part
61
Subpart
L
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
record
keeping
and
reporting
requirements
are
coke
by­
product
recovery
plants
(
SIC
Code
3312:
Steel
Works
and
Blast
Furnaces)
that
commenced
construction,
modification,
or
reconstruction
after
September
14,
1989.

4(
b)
INFORMATION
REQUESTED
All
data
in
this
ICR
that
is
recorded
and/
or
reported
is
required
by
40
CFR
Part
61
Subpart
L
Coke
By­
product
Recovery
Plants.

A
source
must
make
the
following
reports
Provide
notification
of
­
construction/
reconstruction/
modification
­
anticipated
startup
­
actual
startup
­
performance
evaluations
­
implementation
of
equipment
leakage
requirements
Report
on
­
performance
tests
­
excess
emissions
­
general
and
maintenance
inspections
Record
­
startups,
shutdowns,
malfunctions,
periods
where
7
monitoring
system
is
inoperative
­
monitoring
data
and
monitoring
system
calibration
checks
b.
Respondent
Activities
­
Read
instructions
­
Install,
calibrate,
and
maintain
control
systems
and
monitoring
equipment
­
Perform
performance
test
­
Write
the
notifications
and
reports
listed
above
­
Enter
information
required
to
be
recorded
above.

Some
of
the
monitoring
equipment
provides
monitoring
parameters
in
an
automated
way
(
e.
g.,
flow
indicators);
however,
personnel
at
the
facility
still
need
to
evaluate
the
data.
Electronic
submissions
are
not
commonly
used
at
this
time.
Although
regulated
agencies
are
encouraging
facilities
to
submit
reports
on
disk.
Records
are
required
to
be
retained
for
2
years.

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
L
benzene
coke
by­
product
recovery
plants:

­
Observes
initial
performance
tests
and
repeat
performance
tests,
if
necessary.

­
Reviews
notifications
and
reports,
including
performance
test
reports,
and
excess
emissions
reports,
required
to
be
submitted
by
industry.

­
Audits
facility
records.

­
Inputs
and
maintains
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
8
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,
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
or
quarterly
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
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
2
years.

5(
c)
Small
Entity
Flexibility
There
are
no
small
businesses
affected
by
this
standard.

5(
d)
Collection
Schedule
The
specific
frequency
for
each
information
collection
activity
within
this
request
is
shown
in
Table
2.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
Table
2
documents
the
computation
of
individual
burdens
for
each
of
the
record
keeping
and
reporting
requirements
applicable
to
the
industry.
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.

6(
a)
Estimating
Respondent
Burden
The
average
annual
burden
to
industry
over
the
next
three
years
from
these
record
keeping
and
reporting
requirements
is
estimated
at
7,083
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
NESHAP
program,
the
previously
approved
ICR,
and
any
comments
received.
9
6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
This
ICR
uses
labor
rates
of
$
21.16
per
hour
plus
110
percent
overhead
(
for
a
total
cost
per
hour
of
$
44.44)
from
the
United
States
Department
of
Commerce
Bureau
of
Labor
Statistics,
March
2000,
Table
2:
Employment
Costs
for
Civilian
Workers
by
Occupational
and
Industry
Group.

ii)
Estimating
Capital
and
Operations
and
Maintenance
Costs
The
only
type
of
industry
costs
associated
with
the
information
collection
activity
in
the
standards
is
labor
cost.
There
are
no
capital
or
operations
and
maintenance
costs.

(
iii)
Capital/
Start­
up
vs.
Operating
and
Maintenance
(
O&
M)
Costs
None
6(
c)
Estimating
Agency
Burden
and
Cost
The
only
Federal
costs
are
user
costs
associated
with
analysis
of
the
reported
information.
Publication
and
distribution
of
the
information
are
part
of
the
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
Federal
government
cost
during
the
three
years
of
the
ICR
is
estimated
to
be
$
17,088.
This
cost
is
based
on
an
average
wage
of
$
22.86
per
hour
and
a
110
percent
overhead
rate
(
for
a
total
cost
per
hour
of
$
48.01).
Details
upon
which
this
estimate
is
based
appear
in
Table
1.
A
breakdown
of
costs
by
cost
category
is
presented
as
follows:

Average
Direct
Personnel
Cost
$
12,888
(
including
overhead)

Other
Direct
Costs
$
4,200
___________

TOTAL
ANNUAL
COST
$
17,088/
yr
10
6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
The
number
of
existing
sources
subject
to
benzene
emissions
from
coke
by­
product
recovery
plants
subpart
L
is
36.
The
number
of
new
sources
subject
to
benzene
Emissions
from
Coke
By­
product
Recovery
Plants
Subpart
L
is
zero.
There
is
no
annual
labor,
capital
and
O&
M
costs
associated
with
this
ICR.
Details
upon
which
this
estimate
is
based
appear
in
Table
2:
Industry
Burden.

6(
e)
Bottom
Line
Burden
Hours
and
Cost
Tables
See
attached
table
6(
f)
Reasons
for
Change
in
Burden
The
decrease
in
burden
from
the
most
recently
approved
ICR
reflects
the
inclusion
of
appropriate
burden
hours
and
costs
within
the
Reporting
&
Recordkeeping
Requirements
of
the
Consolidated
Federal
Air
Rule
(
CAR)
for
the
Synthetic
Organic
Chemical
Manufacturing
Industry,
EPA
ICR
No.
1854.

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
respondent
burden,
including
through
the
use
of
automated
collection
techniques
to
the
Director,
Collection
Strategies
Division,
U.
S.
Environmental
Protection
Agency
(
2822),
1200
Pennsylvania
Ave.,
N.
W.,
Washington,
D.
C.
20460;
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
1080.10
and
OMB
control
number
2060­
0185
in
any
correspondence.
11
Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.

Section
B
(
Subpart
Y)

1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
ICR
for
NESHAP,
SUBPART
Y
­
Benzene
Emissions
from
Benzene
Storage
Vessels
1(
b)
Short
Characterization/
Abstract
The
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
for
Benzene
Emissions
from
Benzene
Storage
Vessels
were
proposed
in
1980
and
withdrawn
by
EPA
on
June
6,
1984
(
49
FR
23558).
These
standards
apply
to
each
storage
vessel
that
is
storing
benzene
with
a
design
storage
capacity
greater
than
or
equal
to
38
cubic
meters
(
10,000
gallons).
Storage
vessels
with
a
design
storage
capacity
less
than
38
cubic
meters
(
10,000
gallons)
are
exempt
from
the
provisions
of
this
subpart.
Storage
vessels
used
for
storing
benzene
at
coke
by­
product
facilities
or
vessels
permanently
attached
to
motor
vehicles
such
as
trucks,
rail
cars,
barges,
or
ships
or
pressure
vessels
designed
to
operate
in
excess
of
204.9
kPa
and
without
emissions
to
the
atmosphere
are
also
exempt
from
this
subpart.
Approximately
4
existing
sources
are
currently
subject
to
the
standard,
and
it
is
estimated
that
no
additional
sources
will
become
subject
to
the
standard
in
the
next
three
years.
This
information
is
being
collected
to
assure
compliance
with
40
CFR
Part
60,
61,
63
Subpart
Y.

All
owners
and
operators
of
new
or
reconstructed
plants
would
also
have
to
respond.
However,
the
burden
of
monitoring,
reporting
and
record
keeping
for
new
benzene
storage
vessels
was
included
in
the
burden
estimate
for
the
New
Source
Performance
Standards
(
NSPS)
for
storage
vessels
at
40
CFR
60,
Subpart
Kb,
which
has
similar
monitoring,
reporting
and
record
keeping
requirements.
To
avoid
double­
counting,
no
burden
for
new
sources
is
estimated
here.

In
the
General
Provisions
of
40
CFR
Part
61
applicable
to
storage
vessels,
up
to
four
separate
one
time­
only
reports
are
required
for
each
owner
or
operator:
notification
of
construction
or
reconstruction,
initial
source
report,
notification
of
physical/
operational
changes,
notification
of
anticipated
and
actual
startup.
These
notifications,
reports,
and
records
are
essential
in
determining
compliance;
and
are
required,
in
general,
of
all
sources
subject
to
NESHAPs.
12
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
2
years
following
the
date
of
such
reports
and
records.
Approximately
4
sources
are
currently
subject
to
the
standard,
and
no
other
additional
sources
are
estimated
to
become
subject
to
the
standard
in
the
next
three
years.
The
cost
of
this
ICR
will
be
$
2,649
dollars.

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.

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

In
the
Administrator's
judgment,
Benzene
from
Storage
Vessels
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
NESHAP
was
promulgated
for
this
source
category
at
40
CFR
Part
61
Subpart
Y.

2(
b)
PRACTICAL
UTILITY/
USERS
OF
THE
DATA
The
control
of
emissions
of
benzene
from
storage
vessels
requires
not
only
the
installation
of
properly
designed
equipment,
but
also
the
operation
and
maintenance
of
that
equipment.
Emissions
of
benzene
from
storage
vessels
are
the
result
of
operation
of
each
storage
vessel
that
is
storing
benzene
with
a
design
storage
capacity
greater
than
or
equal
to
38
cubic
meters
(
10,000
gallons).
These
standards
rely
on
the
capture
reduction
of
benzene
emissions
by
vapor
recovery
systems
(
VRS).
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
pollution
control
devices
are
properly
installed
and
operated
and
the
standard
is
being
met.
These
records
and
reports
are
made
to
ensure
compliance
with
the
13
standard
on
a
continuous
basis.
Quarterly
excess
emission
reports
are
required
for
closed­
vent
systems
with
control
devices.
The
frequencies
of
these
reports
were
chosen
by
the
Agency
as
the
least
frequent
periods
that
still
provide
an
adequate
margin
of
assurance
that
facilities
subject
to
the
standard
will
not
operate
for
extended
periods
in
violation
of
the
standard.
Data
collection
and
reporting
on
a
less
frequent
basis
would
decrease
the
margin
of
assurance
that
facilities
are
in
compliance
with
the
standard.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
3(
a)
Nonduplication
The
record
keeping
and
reporting
requested
is
required
under
40
CFR
Part
61
Subpart
Y.
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
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
July
12,
1999
(
64
FR
37530).

3(
c)
Consultations
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.

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
record
keeping
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
record
keeping
requirements
contained
in
40
CFR
Part
61
Subpart
Y
or
otherwise
pertinent
to
this
request
violates
any
of
the
regulations
established
by
OMB
in
5
CFR
1320.6.
14
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
record
keeping
requirements
contained
in
(
40
CFR
Part
61
Subpart
Y
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
record
keeping
and
reporting
requirements
are
Petroleum
Refining
(
SIC
Code
2911),
Plastics
Materials
and
Synthetic
Resins,
Synthetic
(
SIC
Code
282
),
and
Industrial
Organic
Chemicals
(
SIC
Code
286)
a
design
storage
capacity
greater
than
or
equal
to
38
cubic
meters
(
10,000
gallons)
for
which
construction
and
operation
commenced
after
September
14,
1989.
An
initial
source
report
is
the
only
one
of
these
record
keeping
and
reporting
requirements
that
would
be
required
from
existing
sources
prior
to
September
14,
1989.

4(
b)
INFORMATION
REQUESTED
(
I)
Data
Items
All
data
in
this
ICR
that
is
recorded
and/
or
reported
is
required
by
40
CFR
Part
61
Subpart
Y
Benzene
Emissions
from
Benzene
Storage
Vessels.

A
source
must
make
the
following
reports
Provide
notification
of:

­
Construction
or
reconstruction
(
61.06
)

­
Construction
or
modification
application
(
61.07)

­
Initial
source
reports
(
61.274)
15
­
Physical/
operational
changes
(
61.15)

­
Anticipated
and
actual
startup
(
61.09)

­
Control
installation
and
refill
at
first
(
61.275)

IFR
degassing
(
61.275)

Report
on:

­
Annual
inspections
for
IFR
(
61.275
a)

­
Periodic
inspections
for
IFR
(
61.275
a)

­
5
or
10
year
internal
inspections
for
IFR
(
61.272
a(
3))

­
Annual
seal
gap
measurements
for
EFR
(
61.272)

­
5
year
seal
gap
measurements
for
EFR
(
61.272)

­
Supplemental
delay
report
(
61.275)

­
Quarterly
excess
emission
for
closed
vent
system
with
control
devices
(
61.275
e)

­
Annual
IFR
internal
inspections
and
EFR
seal
gap
(
61.272)

Record
­
Inspections
for
2
years
(
61.276a)

­
Dimension
and
capacity
of
the
storage
vessel,
for
life
(
61.276b)

­
Operating
plan
of
the
control
device,
for
life
(
61.276b)

­
Monitored
parameters
and
maintenance
for
2
years.
(
61.276)

­
Information
on
closed
vent
systems
with
control
devices
(
61.276)

b.
Respondent
Activities
­
Read
Instructions
16
­
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;

­
developing,
acquiring,
installing,
and
utilizing
technology
and
systems
for
the
purpose
of
processing
and
maintaining
information;

­
developing,
acquiring,
installing,
and
utilizing
technology
and
systems
for
the
purpose
of
disclosing
and
providing
information;

­
adjusting
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;

­
training
personnel
to
be
able
to
respond
to
a
collection
of
information;

­
transmitting,
or
otherwise
disclosing
the
information
Records
are
required
to
be
retained
for
2
Years.

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
Y
Benzene
Emissions
from
Benzene
Storage
Vessels
­
Observes
initial
performance
tests
and
repeat
performance
tests
if
necessary
­
Reviews
notifications
and
reports,
including
performance
test
reports,
and
excess
emissions
reports,
required
to
be
submitted
by
industry
­
Audits
facility
records
­
Inputs
and
maintains
data
in
the
Aerometric
Information
Retrieval
System
(
AIRS)
database
5(
b)
Collection
Methodology
and
Management
17
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,
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
or
quarterly
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
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
There
are
no
small
businesses
affected
by
this
standard.

5(
d)
Collection
Schedule
The
specific
frequency
for
each
information
collection
activity
within
this
request
is
shown
on
Table
2.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
Table
2
documents
the
computation
of
individual
burdens
for
each
of
the
record
keeping
and
reporting
requirements
applicable
to
the
industry.
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.

6(
a)
Estimating
Respondent
Burden
The
average
annual
burden
to
industry
over
the
next
three
years
from
these
record
keeping
and
reporting
requirements
is
estimated
at
48
person­
hours.
These
hours
are
based
on
Agency
18
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(
b)
Estimating
Respondent
Costs
(
I)
Estimating
Labor
Costs
This
ICR
uses
labor
rates
of
$
21.16
per
hour
plus
110
percent
overhead
(
for
a
total
cost
per
hour
of
$
44.44)
from
the
United
States
Department
of
Commerce
Bureau
of
Labor
Statistics,
March
2000,
Table
2:
Employment
Costs
for
Civilian
Workers
by
Occupational
and
Industry
Group.

(
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.

(
iii)
Capital/
Start­
up
vs.
Operating
and
Maintenance
(
O&
M)
Costs
None
6(
c)
Estimating
Agency
Burden
and
Cost
The
only
Federal
costs
are
user
costs
associated
with
analysis
of
the
reported
information.
Publication
and
distribution
of
the
information
are
part
of
the
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
Federal
Government
cost
during
the
three
years
of
the
ICR
is
estimated
to
be
$
17,088.
This
cost
is
based
on
an
average
wage
of
$
22.86
per
hour
and
a
110
percent
overhead
rate
(
for
a
total
cost
per
hour
of
$
48.01).
Details
upon
which
this
estimate
is
based
appear
in
Table
1.
A
breakdown
of
costs
by
cost
category
is
presented
as
follows:

Average
Direct
Personnel
Cost
$
12,888
(
including
overhead)

Other
Direct
Costs
$
4,200
___________

TOTAL
ANNUAL
COST
$
17,088/
yr
19
6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
The
number
of
existing
sources
subject
to
Benzene
Emissions
from
Benzene
Storage
Vessels
subpart
Y
is
4.
The
number
of
new
sources
subject
to
Benzene
Emissions
from
Benzene
Storage
Vessels
subpart
Y
is
zero.
There
is
no
annual
labor,
capital
and
O&
M
costs
associated
with
this
ICR.
Details
upon
which
this
estimate
is
based
appear
in
Table
2:
Industry
Burden.

6(
e)
Bottom
Line
Burden
Hours
and
Cost
Tables
See
attached
table
6(
f)
Reasons
for
Change
in
Burden
The
decrease
in
burden
from
the
most
recently
approved
ICR
reflects
the
inclusion
of
appropriate
burden
hours
and
costs
within
the
Reporting
&
Recordkeeping
Requirements
of
the
Consolidated
Federal
Air
Rule
(
CAR)
for
the
Synthetic
Organic
Chemical
Manufacturing
Industry,
EPA
ICR
No.
1854.

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
respondent
burden,
including
through
the
use
of
automated
collection
techniques
to
the
Director,
Collection
Strategies
Division,
U.
S.
Environmental
Protection
Agency
(
2822),
1200
Pennsylvania
Ave.,
N.
W.,
Washington,
D.
C.
20460;
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
1080.10
and
OMB
control
number
2060­
0185
in
any
correspondence.

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