1
SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
STANDARDS
OF
PERFORMANCE
National
Emission
Standards
for
Hazardous
Air
Pollutants
Subpart
R:
Gasoline
Distribution
Facilities
(
Stage
I)

1.
Identification
of
the
Information
Collection
1(
a)
Identification
of
the
Information
Collection
ICR
for
NESHAP,
Subpart
R
­
Information
Requirements
for
Gasoline
Distribution
Facilities.

1(
b)
Short
Characterization/
Abstract
Respondents
are
owners
or
operators
of
new
or
existing
pipeline
breakout
stations
or
bulk
gasoline
terminals
subject
to
the
NESHAP.
Respondents
are
required
to
submit
one­
time
reports
of
start
of
construction,
anticipated
and
actual
startup
dates,
and
physical
or
operational
changes
to
existing
facilities.
Reports
of
initial
performance
tests
at
bulk
terminal
loading
racks
are
also
required
and
are
necessary
to
show
that
the
installed
control
devices
are
meeting
the
emission
limitations
required
by
the
NESHAP.
Annual
reports
of
storage
vessel
inspections
at
all
affected
facilities
are
required.
In
addition,
respondents
must
submit
semiannual
startup,
shutdown,
and
malfunction
reports,
semiannual
excess
emissions
and
continuous
monitoring
system
performance
reports,
and
semiannual
reports
of
equipment
leaks
not
repaired
within
5
days
or
loadings
of
gasoline
cargo
tanks
for
which
vapor
tightness
documentation
is
not
on
file.
Quarterly
excess
2
emissions
reports
are
required
for
control
device
monitoring
parameter
exceedances,
equipment
leaks
for
which
timely
repair
is
not
made,
and
reloadings
of
nonvapor
tightness
certified
cargo
tanks.
All
affected
bulk
terminals
must
maintain
records
of
the
cargo
tank
vapor
tightness
test
data
on
the
facility
premises.
All
records
are
to
be
maintained
for
at
least
5
years.

All
reports
are
to
be
submitted
to
the
respondent's
State
or
local
agency,
whichever
has
been
delegated
enforcement
authority
by
the
EPA.
The
information
is
to
be
used
to
determine
whether
all
sources
subject
to
the
NESHAP
are
achieving
the
standards.

2.
Need
for
and
Use
of
the
Collection
2(
a)
Need/
Authority
for
the
Collection
The
U.
S.
Environmental
Protection
Agency
(
EPA)
is
charged
under
Section
112
of
the
Clean
Air
Act
(
CAA
or
Act)
(
Attachment
1),
as
amended,
to
establish
national
emission
standards
for
hazardous
air
pollutants
(
NESHAP).
Section
114
of
the
Act
allows
the
Administrator
to
require
inspections,
monitoring,
and
entry
into
facilities
to
ensure
compliance
with
a
Section
112
emission
standard.

Section
114(
a)
specifically
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),
and
(
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
3
compliance
certifications,
and
(
G)
provide
such
other
information
as
he
may
reasonably
require.

Effective
enforcement
of
this
rule
is
necessary
due
to
the
hazardous
nature
of
benzene
(
a
known
human
carcinogen)
and
the
toxic
nature
of
the
other
10
HAP's
emitted
from
gasoline
distribution
facilities.
Certain
records
and
reports
are
necessary:
(
1)
to
enable
the
EPA
to
identify
new
and
existing
sources
subject
to
the
standards,
and
(
2)
to
assist
the
EPA
and
State
agencies
to
which
enforcement
has
been
delegated
in
determining
compliance
with
the
standards.

2(
b)
Practical
Utility/
Users
of
the
Data
The
information
will
be
used
by
agency
enforcement
personnel
to:
(
1)
identify
sources
subject
to
the
standards;
(
2)
ensure
that
leakage
emissions
from
cargo
tanks
and
process
piping
equipment
components
(
both
liquid
and
vapor)
during
loading
are
being
minimized;
(
3)
ensure
that
emission
control
devices
are
being
properly
operated
and
maintained;
and
(
4)
ensure
that
emissions
from
storage
vessels
are
minimized
and
rim
seal
and
fitting
defects
are
repaired
on
a
timely
basis.

In
addition,
records
and
reports
are
necessary
to
enable
the
EPA
to
identify
facilities
that
may
not
be
in
compliance
with
the
standards.
Based
on
reported
information,
the
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
the
EPA
as
to
whether
facility
personnel
are
operating
and
maintaining
control
equipment
properly.

3.
Non
duplication,
Consultations,
and
Other
Collection
Criteria
3(
a)
Non
duplication
Some
of
the
facilities
subject
to
this
NESHAP
will
also
be
subject
to
requirements
under
NSPS
Subparts
K,
Ka,
Kb,
VV,
and
XX.
The
burden
requested
for
this
NESHAP
does
not
4
duplicate
any
of
the
burden
accounted
for
under
those
NSPS
subparts.

Certain
reports
required
by
State
or
local
agencies
may
duplicate
information
required
by
the
standards.
In
such
cases,
a
copy
of
the
report
submitted
to
the
State
or
local
agency
may
be
sent
to
the
Administrator
in
lieu
of
the
report
required
by
the
standards.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
A
federal
register
notice
was
published
on
August
17,
2000
soliciting
comments
on
burden
estimates
for
this
ICR.
No
comments
were
received.

3(
c)
Consultations
The
bulk
terminal
and
pipeline
breakout
station
reporting
and
record
keeping
requirements
were
discussed
with
numerous
representatives
of
the
petroleum
marketing
industry
(
including
owners
of
pipeline
breakout
stations)
during
the
development
of
the
NSPS
for
bulk
terminals,

during
the
development
of
national
standards
for
benzene
emissions
from
gasoline
marketing
operations,
and
during
this
NESHAP
development.

3(
d)
Effects
of
Less
Frequent
Collection
The
reporting
requirements
for
facilities
subject
to
the
NESHAP
consist
of
certain
onetime
reports
and
a
minimal
amount
of
periodic
record
keeping
and
reporting.
At
new
and
existing
bulk
terminals,
monthly
visual
(
non­
instrument)
inspections
and
corresponding
records
and
reports
of
the
loading
racks
and
process
piping
equipment
components
are
required
(
storage
vessels
require
annual
inspections
and
associated
records
and
reports).
If
this
information
were
collected
less
frequently,
the
main
consequence
would
be
poor
operation
and
maintenance
of
equipment
components
and
storage
vessels.
Consequently,
increased
HAP
emissions
could
result.

The
same
is
true
for
visual
inspections
of
equipment
components
and
the
inspection
of
storage
vessels
at
pipeline
breakout
stations.
5
At
bulk
gasoline
terminals,
monitoring
an
operating
parameter
of
the
control
device
on
a
continuous
basis
is
the
only
means
of
ensuring
that
the
device
is
continuing
to
meet
the
emission
limit.
The
effect
of
not
requiring
this
monitoring
could
be
increased
HAP
emissions.

3(
e)
General
Guidelines
The
final
rule
requires
records
to
be
retained
for
5
years,
which
is
consistent
with
the
Part
63
General
Provisions
and
the
Part
70
operating
permit
requirements
(
Title
V).
All
of
the
facilities
affected
by
this
NESHAP
are
required
to
obtain
an
operating
permit
(
with
or
without
the
issuance
of
this
NESHAP).
None
of
the
other
guidelines
in
5
C.
F.
R.
§
1320.6
is
being
exceeded.

3(
f)
Confidentiality
Any
information
submitted
to
the
Agency
for
which
a
claim
of
confidentiality
is
made
will
be
safeguarded
according
to
Agency
policies
as
set
forth
in
Title
40,
Chapter
1,
Part
2,
Subpart
B­

­
Confidentiality
of
Business
Information
(
see
40
C.
F.
R.
Part
2;
40
FR
36902,
September
1,
1976;

amended
by
43
FR
39999,
September
28,
1978;
43
FR
42251,
September
28,
1978;
44
FR
17674,
March
23,
1979).

3(
g)
Sensitive
Questions
This
section
is
not
applicable.
Information
to
be
collected
has
been
determined
not
to
be
of
a
sensitive
nature.

4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
SIC
Codes
Respondents
are
owners
or
operators
of
affected
pipeline
breakout
stations
and
bulk
terminals
subject
to
the
NESHAP.
The
SIC
codes
for
the
respondents
affected
by
the
standards
6
include
4226,
4400,
5169,
5171,
and
5172.

4(
b)
Information
Requested
(
i)
Data
items,
including
record
keeping
requirements
(
1)
Bulk
Gasoline
Terminals.
The
following
types
of
one­
time
reports
are
required
for
bulk
terminals
affected
by
the
NESHAP.

°
For
existing
sources,
a
report
filed
within
1
year
subsequent
to
the
effective
date
of
the
NESHAP,
notifying
the
Administrator
that
the
facility
is
subject
to
the
relevant
standards.
Information
to
be
provided
in
the
report
is
detailed
in
40
C.
F.
R.
§
63.9(
b)(
2)
of
Subpart
A,
General
Provisions.

°
For
new
sources
[
for
which
approval
of
construction
or
reconstruction
is
not
required
under
40
C.
F.
R.
§
63.5(
d)],
a
report
filed
within
15
days
after
startup
of
the
source,
notifying
the
Administrator
that
the
facility
is
subject
to
the
relevant
standards.
Information
to
be
provided
in
the
report
is
detailed
in
40
C.
F.
R
§
63.9(
b)(
3).

°
Notification
of
anticipated
construction
or
reconstruction
of
a
source
subject
to
a
relevant
standard
not
later
than
180
days
prior
to
commencement
of
construction
or
reconstruction
as
indicated
in
40
C.
F.
R
§
63.9(
b)(
5).

°
Notification
of
anticipated
date
of
initial
startup
not
more
than
60
days
nor
less
than
30
days
prior
to
such
date.
40
C.
F.
R
§
63.9(
b)(
4)(
iv).

°
Notification
of
the
actual
date
of
startup,
within
15
days
after
such
date.
40
C.
F.
R
§
63.9(
b)(
4)(
v).

°
Notification
of
construction
or
reconstruction
not
later
than
30
days
after
the
change
is
commenced.
40
C.
F.
R.
§
63.9(
b)(
4)(
iii).

°
Notification
of
installation
of
a
new
control
device
or
reconstruction
of
an
existing
control
device
within
180
days
before
the
installation
or
reconstruction
is
planned
to
commence.
40
C.
F.
R.
§
63.5(
b)(
6)
and
40
C.
F.
R.
§
63.5(
d)(
1).

°
Within
180
days
after
initial
startup,
installation
of
a
control
device,
or
refurbishment
of
an
existing
control
device,
the
owner
or
operator
of
the
facility
must
conduct
a
performance
test
and
furnish
the
Administrator
with
a
written
report.
40
C.
F.
R.
§
63.7(
a).

°
The
owner
or
operator
of
an
affected
facility
must
notify
the
Administrator
at
least
60
days
prior
to
the
date
of
a
performance
test.
40
C.
F.
R.
§
63.9(
e).
7
°
A
request
for
an
extension
of
compliance
report
must
be
submitted
if
the
owner
or
operator
cannot
comply
with
the
standard
by
the
designated
date.
40
C.
F.
R.
§
63.9(
c).

°
The
owner
or
operator
must
report
any
reconstruction
of
an
affected
facility
as
defined
in
40
C.
F.
R.
§
63.5.

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

°
At
new
and
existing
facilities,
monthly
visual
inspection
data
on
gasoline
transfer
and
vapor
collection
and
processing
equipment.
Records
and
reports
are
to
be
kept
as
specified
in
40
C.
F.
R.
§
63.428(
e)
and
(
f).

°
Annual
inspections
of
storage
vessels
are
to
be
made
and
records
kept
and
reports
filed
as
specified
in
40
C.
F.
R.
§
60.115b.

°
Records
are
to
be
maintained
and
kept
up­
to­
date
of
the
cargo
tank
vapor
tightness
data
in
accordance
with
40
C.
F.
R.
§
63.428(
b).

°
A
continuous
record
of
operating
parameter
monitoring
data
is
to
be
kept,
and
exceedances
of
the
monitored
operating
parameter
are
to
be
reported
semiannually
pursuant
to
40
C.
F.
R.
§
63.428(
c)(
1)
and
40
C.
F.
R.
§
63.428(
g)(
1).

°
Records
required
by
this
NESHAP
must
be
retained
by
the
owner
or
operator
for
5
years
40
C.
F.
R.
§
63.10(
b).

°
Annual
reports
stating
non­
applicability
of
the
regulation
are
required
from
area
sources
within
50
percent
of
the
major
source
threshold
as
specified
in
40
C.
F.
R.
§
63.428(
i).

These
data
will
be
viewed
and
analyzed
by
Agency
personnel
during
periodic
visits,

approximately
once
a
year,
to
the
respondents'
terminals.

(
2)
Pipeline
breakout
stations.
The
following
types
of
one­
time
reports
are
required
for
pipeline
breakout
stations
subject
to
the
NESHAP.

°
For
existing
sources,
a
report
filed
within
1
year
subsequent
to
the
effective
date
of
the
NESHAP,
notifying
the
Administrator
that
the
facility
is
subject
to
the
relevant
standards.
Information
to
be
provided
in
the
report
is
detailed
in
40
C.
F.
R.
§
63.9(
b)(
2)
of
Subpart
A,
General
Provisions.
8
°
For
new
sources
[
for
which
approval
of
construction
or
reconstruction
is
not
required
under
40
C.
F.
R.
§
63.5(
d)],
a
report
filed
within
15
days
after
startup
of
the
source,
notifying
the
Administrator
that
the
facility
is
subject
to
the
relevant
standards.
Information
to
be
provided
in
the
report
is
detailed
in
40
C.
F.
R.
§
63.9(
b)(
3).

°
Notification
of
anticipated
construction
or
reconstruction
of
a
source
subject
to
a
relevant
standard
not
later
than
180
days
prior
to
commencement
of
construction
or
reconstruction.
40
C.
F.
R.
§
63.9(
b)(
5).

°
Notification
of
anticipated
date
of
initial
startup
not
more
than
60
days
nor
less
than
30
days
prior
to
such
date.
40
C.
F.
R.
§
63.9(
b)(
4)(
iv).

°
Notification
of
actual
date
of
initial
startup
within
15
days
after
such
date.
40
C.
F.
R.
§
63.9(
b)(
4)(
v).

°
Notification
of
construction
or
reconstruction
not
later
than
30
days
after
the
change
is
commenced.
40
C.
F.
R.
§
63.9(
b)(
4)(
iii).

°
A
request
for
an
extension
of
compliance
report
must
be
submitted
if
the
owner
or
operator
cannot
comply
with
the
standards
by
the
designated
date.
40
C.
F.
R.
§
63.9(
c).

°
The
owner
or
operator
must
report
any
reconstruction
of
an
affected
facility
as
defined
in
40
C.
F.
R
§
63.5.

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

°
At
new
and
existing
facilities,
monthly
visual
inspection
data
on
gasoline
transfer
and
vapor
collection
and
processing
equipment.
Records
and
reports
are
to
be
kept
as
specified
in
40
C.
F.
R.
§
63.428(
e)
and
(
f).

°
Annual
inspections
of
storage
vessels
are
to
be
made
and
records
kept
and
reports
filed
as
specified
in
40
C.
F.
R.
§
60.115b.

°
Records
required
by
this
NESHAP
must
be
retained
by
the
owner
or
operator
for
5
years.
40
C.
F.
R.
§
63.10(
b).

°
Annual
reports
stating
non­
applicability
of
the
regulation
are
required
from
area
sources
within
50
percent
of
the
major
source
threshold
as
specified
in
40
C.
F.
R.
§
63.428(
i).

These
data
will
be
viewed
and
analyzed
by
Agency
personnel
during
periodic
visits,
9
approximately
once
a
year,
to
the
respondents'
pipeline
stations.

(
ii)
Respondent
Activities.

The
respondent
activities
required
by
the
standards
are
provided
under
the
first
column
of
Tables
1A
and
1B
of
Section
6(
a).

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
C.
F.
R.
Subpart
"
R",
National
Emissions
Standards
for
Hazardous
Air
Pollutants
for
Source
Categories:
Gasoline
Distribution
(
Stage
I).

­
Observes
initial
and
repeat
performance
tests
­
Reviews
notifications
and
reports,
including
excess
emissions
reports,
required
to
be
submitted
by
industry.

­
Audits
facility
records
­
Compiles
data
in
the
AIRS
database
5(
b)
Collection
Methodology
and
Management
Following
notification
of
startup,
the
reviewing
authority
might
inspect
the
source
to
check
if
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
obtained
during
periodic
visits
by
Agency
personnel
from
records
maintained
by
the
respondents
are
10
tabulated
and
published
for
internal
Agency
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
the
Aerometric
Information
Retrieval
System
(
AIRS)
Facility
Subsystem
(
AFS)
which
is
operated
and
maintained
by
EPA's
Office
of
Air
Quality
Planning
and
Standards.
The
AFS
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
AFS
for
tracking
air
pollution
compliance
and
enforcement
by
local
and
State
regulatory
agencies,
EPA
Regional
Offices
and
Headquarters.

EPA
can
edit,
store,
retrieve
and
analyze
the
data
via
PC
terminals.

5(
c)
Small
Entity
Flexibility
(
i)
Bulk
Gasoline
Terminals
Even
though
the
record­
keeping
requirements
are
the
same
for
small
and
large
businesses,

the
Agency
considers
these
requirements
the
minimum
needed
to
ensure
compliance
and,

therefore,
cannot
reduce
them
further
for
small
businesses.
Construction,
modification,
and
reconstruction
reports
take
very
little
time
to
complete
and
are
filed
only
once.
Equipment
leak
monitoring
and
storage
vessel
inspection
records
are
brief
and
tank
truck
vapor
tightness
documentation
will
be
supplied
by
cargo
tank
operators
and
kept
at
the
terminal
for
each
tank
currently
using
the
terminal.

(
ii)
Pipeline
Breakout
Stations
Owners
or
operators
of
small
pipeline
breakout
stations
are
required
to
maintain
records
and
report
inspections
of
storage
vessels
in
the
same
manner
as
bulk
gasoline
terminals,
and,

therefore,
the
same
level
of
flexibility
applies.
11
5(
d)
Collection
Schedule
Information
contained
in
the
one­
time­
only
reports
will
be
entered
into
the
AIRS
facility
subsystem.
Data
obtained
during
periodic
visits
by
Agency
personnel
from
records
maintained
by
the
respondents
and
reports
submitted
by
the
respondents
to
the
EPA
will
be
tabulated
and
published
for
internal
EPA
use
in
compliance
enforcement
programs.
A
schedule
for
the
collection
of
information
and
publication
of
data
is
not
applicable
because
reports
and
record
keeping
are
triggered
by
action
of
the
respondents.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
Tables
1A
and
1B
document
the
computation
of
individual
burdens
for
each
of
the
record
keeping
and
reporting
requirements
applicable
to
the
respondents
complying
with
this
standard.

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
(
i)
Bulk
Gasoline
Terminals
The
average
annual
burden
for
bulk
gasoline
terminals
over
the
next
three
years
from
these
record
keeping
and
reporting
requirements
is
estimated
at
31,797
person­
hours,
as
indicated
in
Table
1B.
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
12
NESHAP
program,
the
previously
approved
ICR,
and
any
comments
received
about
time
to
prepare
reports.

For
the
purposes
of
these
estimates,
a
controlled
bulk
terminal
is
one
that
has
a
vapor
processor
installed
at
its
loading
racks
which
complies
with
an
emission
limit
of
80
mg
of
total
organic
compounds
per
liter
of
gasoline
loaded.
Cargo
tanks
that
are
presently
required
to
have
annual
vapor
tightness
tests
are
classified
as
currently
tested.
The
number
of
terminals
estimated
to
be
constructed
or
changed
was
based
on
industry
growth
projections.

NUMBER
OF
EMISSION
SOURCES
AT
BULK
TERMINALS
SUBJECT
TO
THE
NESHAP
Source
Type
Total
Major*
Only
Number
of
Bulk
Terminals
1,024
243
13
Number
of
Loading
Racks
Controlled
Meeting
10
mg/
l
Meeting
NSPS
level
Meeting
CTG
level
Uncontrolled
1,024
727
338
123
266
297
243
131
61
22
48
112
Number
of
Cargo
Tanks
Currently
tested
Not
tested
43,900
31,169
12,731
10,439
7,412
3,027
Number
of
Storage
Tanks
Meeting
NSPS
&
CTG
levels
External
floating
roof
tanks
with
primary
seals
Uncontrolled
fixed­
roof
tanks
8,032
4,534
2,426
1,072
1,910
1,078
577
255
Number
of
Equipment
Components**

100,000
gal/
day
facility
250,000
gal/
day
facility
500,000
gal/
day
facility
1,000,000
gal/
day
facility
Pump
Seals
10
15
15
20
Valves
290
350
450
500
*"
Major"
sources
are
those
that
emit
10
tons/
year
or
more
of
a
listed
pollutant
or
25
tons
or
more
of
a
combination
of
pollutants.

**
Varies
by
facility.
Values
presented
are
model
plant
estimates.
Additional
components
(
e.
g.,
open­
ended
lines
and
connectors)
are
not
shown
here.

(
ii)
Pipeline
Breakout
Stations
The
average
annual
burden
for
pipeline
breakout
stations
over
the
next
three
years
from
these
record
keeping
and
reporting
requirements
is
estimated
at
778
person­
hours,
as
indicated
in
Table
1A.
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
about
time
to
14
prepare
reports.

NUMBER
OF
EMISSION
SOURCES
AT
PIPELINE
BREAKOUT
STATIONS
SUBJECT
TO
THE
NESHAP
Source
Type
Total
Major*
Only
Number
of
Breakout
Stations
270
20
Number
of
Storage
Tanks
Meeting
NSPS
&
CTG
levels
External
floating
roof
tanks
with
primary
seals
Uncontrolled
fixed­
roof
tanks
3,300
1,639
1,288
373
244
121
95
28
Number
of
Equipment
Components**

Stations
with
10
storage
tanks
Stations
with
15
storage
tanks
Pump
Seals
20
35
Valves
2,640
7,920
*"
Major"
sources
are
those
that
emit
10
tons/
year
or
more
of
a
listed
pollutant
or
25
tons
or
more
of
a
combination
of
pollutants.

**
Varies
by
facility.
Values
presented
are
model
plant
estimates.
Additional
components
are
not
shown
here.

6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
This
ICR
uses
the
labor
rate
of
$
39.77
per
hour
from
the
United
States
Department
of
Commerce
Bureau
of
Labor
Statistics
Employment
Costs
for
Civilian
Workers
by
Occupational
and
Industry
Group.
The
costs
to
conduct
this
effort
have
been
calculated
on
the
basis
of
$
18.94
per
hour
plus
110
percent
overhead.

(
ii)
Estimating
Capital
and
Operations
and
Maintenance
Costs
There
are
no
new
sources
expected
over
the
next
three
years,
therefore,
the
capital
startup
costs
for
this
regulation
is
estimated
to
be
$
0.
15
(
iii)
Capital/
Start­
up
Operating
and
Maintenance
(
O&
M)
Costs
A
representative
of
the
Petroleum
Marketers
Association
of
America
(
PMAA)
was
consulted
regarding
the
annual
operation
and
maintenance
costs
associated
with
the
continuous
emission
monitor
requirement,
number
14(
b),
form
83­
I.
PMAA
indicated
an
annual
cost
of
$
3,500
per
facility,
to
monitor
and
repair
the
equipment,
as
well
as
the
energy
cost
to
run
the
equipment.
Please
note,
only
243
bulk
gasoline
terminals
were
counted
towards
the
total
number
of
facilities,
due
to
the
fact
that
there
is
no
CEM
requirement
for
the
20
pipeline
breakout
stations.
Assume
cost
calculated
as
follows:

$
3,500
X
243
facilities
=
$
850,500
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
Aerometric
Information
Retrieval
System
(
AIRS)
Facility
Subsystem
(
AFS)
which
is
operated
and
maintained
by
EPA's
Office
of
Air
Quality
Planning
and
Standards.
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
next
3
years
of
the
ICR
is
estimated
to
be
$
428,258.
This
cost
is
based
on
an
average
wage
of
a
GS­
10,
step
1
employee
for
technical
level
work
performed
plus
the
average
wage
of
a
GS­
14,
step
1
employee
for
litigation
work
performed.
The
costs
to
conduct
this
effort
have
been
calculated
on
the
basis
of
$
18.24
and
$
33.76
per
hour,
respectively,
plus
110
percent
overhead.
Details
upon
which
this
estimate
is
based
appear
in
Tables
2A
and
2B.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
16
The
number
of
existing
sources
subject
to
the
National
Emission
Standards
for
Hazardous
Air
Pollutants
for
Source
Categories:
Gasoline
Distribution
(
Stage
I),
40
C.
F.
R.
Part
63,
Subpart
R
is
263
(
243
bulk
gasoline
terminals
+
20
pipeline
breakout
stations)
with
no
new
sources
expected
due
to
no
projected
growth
for
the
bulk
gasoline
terminal
industry.
The
labor
estimates
used
in
Tables
1A
and
1B
were
derived
from
standard
estimates
based
on
EPA's
experience
with
other
standards.
The
average
annual
burden
to
the
industry
over
the
next
three
years
from
these
record
keeping
and
reporting
requirements
is
estimated
at
32,575
person­
hours.
The
respondent
costs
have
been
calculated
on
the
basis
of
$
18.94
per
hour,
plus
110
percent
overhead.
The
average
annual
burden
to
industry
over
the
next
three
years
of
the
ICR
is
estimated
to
be
$
1,295,518.
Details
upon
which
this
estimate
is
based
appear
in
Tables
1A
and
1B.

6(
e)
Bottom
Line
Burden
Hours
And
Costs
Tables
(
i)
Respondent
Tally
See
Tables
1A
and
1B.

(
ii)
The
Agency
Tally
See
Tables
2A
and
2B.

(
iii)
Variations
in
the
Annual
Bottom
Line
Annual
burden
costs
for
the
industry
(
tables
1A
and
1B)
and
annual
burden
costs
for
the
Federal
Government
(
tables
2A
and
2B)
increase
for
this
ICR
due
to
increase
in
current
hourly
wage
rates
only.
17
6(
f)
Reasons
For
Change
In
Burden
Burden
hours
remain
unchanged.
However,
the
decrease
in
industry
burden
cost
from
the
most
recently
approved
ICR
is
due
to
more
accurate
hourly
rate
estimates
obtained
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;
Column
2,
wages
and
salaries.

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
C.
F.
R.
Part
9
and
48
C.
F.
R.
Chapter
15.
18
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
Sandy
Farmer,
U.
S.
Environmental
Protection
Agency,
Collection
Strategies
Division
(
Mail
Code
2822),
1200
Pennsylvania
Avenue,

N.
W.,
Washington,
D.
C.
20460;
and
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
N.
W.,
Washington,
D.
C.
20503,
Attention:
Desk
Officer
for
EPA.
Include
the
EPA
ICR
number
1659.04
and
OMB
control
number
2060­
0325
in
any
correspondence.
19
TABLE
1A.
ANNUAL
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
OF
THE
NESHAP
AT
PIPELINE
BREAKOUT
STATIONS
Burden
Item
Hours
per
Occurrence
(
A)
Number
of
Occurrences
per
Respondent
(
B)
Number
of
Respondents
(
C)
Person­
hours
(
D=
AxBxC)
Annual
Cost,
$

(
E=
Dx$
39.77)

1.
Applications
NA
2.
Surveys
&
studies
NA
3.
Reporting
requirements
A.
Read
instructions
1
1
20
20
795
B.
Required
activities
Initial
performance
test
NA
Storage
tank
seal
and
seal
gap
inspectionsa
16
1
10
160
6,363
C.
Create
information
see
3B
D.
Gather
information
see
3B
E.
Report
preparation
Initial
notification
2
1
0
0
0
Notification
of
compliance
status
8
1
0
0
0
Semiannual
reports
8
2
20
320
12,726
Notification
of
constr./
reconstr.
2
1
2
4
159
Notification
of
anticipated
startup
2
1
1
2
80
Notification
of
actual
startup
2
1
1
2
80
Notification
of
perf.
test
and
CMS
evaluation
NA
Area
source
reporting
of
complianceb
1
1
125
125
4,971
4.
Recordkeeping
requirements
A.
Read
instructions
see
3A
B.
Plan
activities
see
3B
C.
Implement
activities
see
3B
D.
Develop
record
system
8
1
0
0
0
E.
Record
information
TABLE
1A.
(
Concluded)

Burden
Item
Hours
per
Occurrence
(
A)
Number
of
Occurrences
per
Respondent
(
B)
Number
of
Respondents
(
C)
Person­
hours
(
D=
AxBxC)
Annual
Cost,
$

(
E=
Dx$
39.77)

20
Record
equipment
subject
to
visual
inspection
requirements
1
1
0
0
0
Record
equipment
leak
data
0.1
12
20
24
954
Record
storage
tank
seal
inspections
1
1
10
10
398
Record
startup,
shutdowns,
and
malfunctions
1
4
10
40
1,591
Area
source
recordkeepingc
0.25
1
125
31.25
1,243
F.
Personnel
training
1
1
20
20
795
G.
Time
for
audits
4
1
5
20
795
TOTAL
BURDEN
AND
COST
778
30,950
aAssumes
that
50%
of
the
20
estimated
existing
major
source
facilities
are
currently
subject
to
requirements
equivalent
to
the
VOL
Storage
NSPS
(
40
CFR
part
60,
subparts
K,
Ka,
and
Kb)
or
storage
tank
CTG's.

bAssumes
that
50%
of
area
source
facilities
will
be
within
50%
of
major
source
threshold
criteria
and
will
be
required
to
submit
annual
certification
of
area
source
status
reports
[(
270
­
20)/
2
=
125
facilities].

cAssumes
that
50%
of
area
source
facilities
will
be
required
to
keep
annual
records
of
their
area
source
status
using
the
screening
equation.
21
TABLE
1B.
ANNUAL
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
OF
THE
NESHAP
AT
BULK
GASOLINE
TERMINALS
Burden
Item
Hours
per
Occurrence
(
A)
Number
of
Occurrences
per
Respondent
(
B)
Number
of
Respondents
(
C)
Person­
hours
(
D=
AxBxC)
Annual
Cost,
$

(
E=
Dx$
39.77)

1.
Applications
NA
2.
Surveys
&
studies
NA
3.
Reporting
requirements
A.
Read
instructions
2
1
243
486
19,328
B.
Required
activities
Initial
performance
test
175
1
0
0
0
Repeat
performance
test
175
1
0
0
0
Storage
tank
seal
and
seal
gap
inspectionsa
16
1
122
1,952
77,631
C.
Create
information
see
3B
D.
Gather
information
see
3B
E.
Report
preparation
Initial
notification
3
1
0
0
0
Notification
of
compliance
status
4
1
0
0
0
Semiannual
reportsb
10
2
97
1,940
77,154
Notification
of
constr./
reconstr.
2
1
15
30
1,193
Notification
of
anticipated
startup
2
1
5
10
398
Notification
of
actual
startup
2
1
5
10
398
Notification
of
perf.
test
and
CMS
evaluation
4
1
28
112
4,454
Area
source
reporting
of
compliancec
1
1
391
391
15,550
TABLE
1B.
(
Continued)

Burden
Item
Hours
per
Occurrence
(
A)
Number
of
Occurrences
per
Respondent
(
B)
Number
of
Respondents
(
C)
Person­
hours
(
D=
AxBxC)
Annual
Cost,
$

(
E=
Dx$
39.77)

22
4.
Recordkeeping
requirements
A.
Read
instructions
see
3A
B.
Plan
activities
see
4C
C.
Implement
activities
File
cargo
tank
inspection
recordsb
0.5
26
146
1,898
75,483
Update
cargo
tank
inspection
recordsb
6
1
146
876
34,839
Cross­
check
cargo
tank
inspection
fileb
6
26
146
22,776
905,802
D.
Develop
record
system
8
1
0
0
0
E.
Record
information
Record
equipment
subject
to
visual
inspection
requirements
1
1
0
0
0
Record
equipment
leak
data
0.1
4
243
97
3,858
Record
storage
tank
seal
inspections
1
1
122
122
4,852
Record
startups,
shutdowns,
and
malfunctionsa
1
4
122
488
19,408
Area
source
recordkeepingd
0.25
1
391
98
3,897
TABLE
1B.
(
Continued)

Burden
Item
Hours
per
Occurrence
(
A)
Number
of
Occurrences
per
Respondent
(
B)
Number
of
Respondents
(
C)
Person­
hours
(
D=
AxBxC)
Annual
Cost,
$

(
E=
Dx$
39.77)

23
F.
Personnel
training
1
1
97
97
3,858
G.
Time
for
audits
6
1
69
414
16,465
TOTAL
BURDEN
AND
COST
31,797
1,264,568
aAssumes
that
50%
of
the
243
estimated
major
source
facilities
are
currently
subject
to
requirements
equivalent
to
the
VOL
Storage
NSPS
(
40
CFR
part
60,

subparts
K,
Ka,
and
Kb)
or
storage
tank
CTG's.

bAssumes
that
40%
of
the
243
estimated
major
source
facilities
are
currently
subject
to
requirements
equivalent
to
the
Bulk
Gasoline
Terminal
NSPS
(
40
CFR
part
60,
subpart
XX).

cAssumes
that
50%
of
area
sources
will
be
within
50%
of
major
source
threshold
criteria
and
will
be
required
to
submit
annual
certification
of
area
source
status
reports
[(
1024
­
243)/
2
=
391
facilities].

dAssumes
that
50%
of
area
sources
(
391
facilities)
will
be
required
to
keep
annual
records
of
their
area
source
status
using
the
screening
equation.
24
TABLE
2A.
ANNUAL
BURDEN
AND
COST
FOR
THE
FEDERAL
GOVERNMENT
TO
IMPLEMENT
THE
NESHAP
AT
PIPELINE
BREAKOUT
STATIONS
Activity
EPA
Hours
per
Occurrence
(
A)
Number
of
Occurrences
(
B)
EPA
Person­
hours
(
D=
AxB)
Annual
Cost,
$

(
E=
Dx$
38.30/$
70.75)

Review
initial
notification
1
0
0
0
Review
notification
of
compliance
status
8
0
0
0
Review
semiannual
reports
8
36
288
11,030
Review
notification
of
constr./
reconstr.
a
0
0
0
0
Review
notification
of
anticipated
startupa
0
0
0
0
Review
notification
of
actual
startupa
0
0
0
0
Litigationb
1,040
1
1,040
73,580
TOTAL
BURDEN
AND
COST
1,328
84,610
aActivity
already
accounted
for
by
the
Organic
Liquid
Storage
NSPS
(
40
CFR
part
60,
subparts
K,
Ka,
and
Kb).

bHourly
wage
is
based
on
average
of
a
GS­
10,
step
1
employee
plus
110%
overhead
except
for
"
Litigation"
activity
which
is
based
on
an
average
of
a
GS­
14,
step
1
employee
plus
110%
overhead.
25
TABLE
2B.
ANNUAL
BURDEN
AND
COST
FOR
THE
FEDERAL
GOVERNMENT
TO
IMPLEMENT
THE
NESHAP
AT
BULK
GASOLINE
TERMINALS
Activity
EPA
Hours
per
Occurrence
(
A)
Number
of
Occurrences
(
B)
EPA
Person­
hours
(
D=
AxB)
Annual
Cost,
$

(
E=
Dx$
38.30/$
70.75)

Review
initial
notification
1
0
0
0
Review
notification
of
compliance
status
10
0
0
0
Review
semiannual
reports
10
486
4,860
186,138
Review
notification
of
constr./
reconstr.
a
0
0
0
0
Review
notification
of
anticipated
startupa
0
0
0
0
Review
notification
of
actual
startupa
0
0
0
0
Review
notification
of
perf.
test
and
CMS
evaluation
1
0
0
0
Attend
initial
performance
testb
8
0
0
0
Attend
repeat
performance
testc
8
0
0
0
Litigationd
1,040
2
2,080
147,160
TOTAL
BURDEN
AND
COST
(
Salary)
6,940
333,298
Travele
10,350
TOTAL
ANNUAL
COST
343,648
aActivity
already
accounted
for
by
the
Bulk
Gasoline
Terminal
NSPS
(
40
CFR
60,
subpart
XX).

bAssumes
EPA
personnel
attend
10%
of
all
performance
tests
[
only
tests
not
covered
by
Bulk
Gasoline
Terminal
NSPS
(
40
CFR
60,
subpart
XX)
are
accounted
for
here].
cAssumes
that
10%
of
performance
tests
must
be
repeated.

dHourly
wage
is
based
on
average
of
a
GS­
10,
step
1
employee
plus
110%
overhead
except
for
"
Litigation"
activity
which
is
based
on
an
average
of
a
GS­
14,
step
1
employee
plus
110%
overhead.

eTravel
cost
based
on
23
one­
day
trips
for
one
person
at
$
400
per
round
trip
plus
$
50
per
diem.
26
