SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
Standards
of
Performance
­
National
Emission
Standards
for
Hazardous
Air
Pollutants
for
Marine
Tank
Vessel
Loading
Operations.
(
40
CFR
Part
63,
Subpart
Y)

1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
ICR
for
NESHAP
for
Marine
Tank
Vessel
Loading
Operations
(
40
CFR
63
Subpart
Y)

1(
b)
Short
Characterization/
Abstract
This
collection
is
for
record
keeping
and
periodic
reporting
information
to
EPA
Regional
Offices
and
delegated
states.
The
information
concerns
compliance
information
for
the
emissions
relating
to
loading
of
marine
tank
vessels
with
petroleum
and
gasoline.
Delegated
states
and
EPA
Regional
Offices
use
the
data
to
determine
compliance
with
the
NESHAP
rule.
The
purpose
is
to
assure
compliance
with
emission
requirements
in
40
CFR
63
subpart
Y.
In
general
records
will
be
stored
on
site
and
shown
to
inspectors
when
requested.
These
will
be
hard
copy
records
for
the
most
part.
Other
information
for
periodic
reports
are
sent
to
the
state
or
to
the
Regional
Office.
It
will
cost
105
facilities,
a
total
of
28,131
hours
each
year
at
a
total
cost
of
$
1,535,817.

In
general,
all
National
Emission
Standards
for
Hazardous
Air
Pollutant
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
the
National
Emission
Standards
for
Hazardous
Air
Pollutant
standards.

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
preparing
the
maintenance
report
or
record.
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
105
sources
are
currently
subject
to
the
standard,
and
no
additional
sources
per
year
will
become
subject
to
the
standard
in
the
next
three
years.
Persons
knowledgeable
about
this
industry
say
there
is
no
growth
in
this
industry,
and
currently,
there
is
extra
capacity
at
most
marine
terminals.
These
estimates
were
verified
with
the
original
writers
of
the
rule.
2
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
(
HAP).
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
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
and
Volatile
Organic
Compounds
(
VOC)
emissions
from
marine
tank
vessel
loading
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
National
Emission
Standards
for
Hazardous
Air
Pollutants
were
promulgated
for
this
source
category
at
40
CFR
Part
63,
Subpart
Y.

2(
b)
Practical
Utility/
Users
of
the
Data
The
control
of
emissions
of
Hazardous
Air
Pollutants
(
HAP)
(
vaporized
crude
oil
or
gasoline)
and
Volatile
Organic
Compounds
(
VOC)
(
vaporized
gasoline)
from
marine
tank
vessel
loading
requires
not
only
the
installation
of
properly
designed
equipment,
but
also
the
operation
and
maintenance
of
that
equipment.
Emissions
of
HAP/
VOC
from
marine
tank
vessel
loading
are
the
result
of
operation
of
the
affected
facilities.
These
standards
rely
on
the
reduction
of
HAP/
VOC
emissions
by
flares
and
other
emission
reduction
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
pollution
control
devices
are
properly
installed
and
operated
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.

The
information
generated
by
the
recordkeeping
and
reporting
requirements
described
in
3
this
ICR
is
used
by
the
Agency
to
ensure
that
facilities
affected
by
the
NESHAP
continue
to
operate
the
control
equipment
and
achieve
compliance
with
the
regulation.
Adequate
monitoring,
recordkeeping,
and
reporting
is
necessary
to
ensure
compliance
with
these
standards,
as
required
by
the
Clean
Air
Act.
The
information
collected
from
recordkeeping
and
reporting
requirements
is
also
used
for
targeting
inspections,
and
is
of
sufficient
quality
to
be
used
as
evidence
in
court.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
The
recordkeeping
and
reporting
requested
is
required
under
40
CFR
Part
63
,
Subpart
Y.

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
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
August
17,
2001.
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.

3(
c)
Consultations
Not
applicable.

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
4
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
marine
tank
vessel
loading
operations
at
marine
terminals.
The
SIC
code
for
the
respondents
affected
by
the
standards
is
SIC
4491.
Standard
Industrial
Classification
which
corresponds
to
the
NAICS
(
The
North
American
Industry
Classification
System)
is
488310
for
operations
of
ports
and
waterfront
terminals,
and
488320
for
marine
cargo
handling.

4(
b)
INFORMATION
REQUESTED
This
rule
requires
affected
facilities
to
maintain
copies
of
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.

(
i)
Data
Items
All
data
in
this
ICR
that
is
recorded
and/
or
reported
is
required
by
the
NESHAP
for
Marine
Tank
Vessel
Loading
(
40
CFR
Part
63,
Subpart
Y).
5
A
source
must
make
the
following
reports:

Reports
for
Regulatory
Citation
Construction/
reconstruction
40
CFR
60.7(
a)(
1),
63.5
Construction
or
modification
application
40
CFR
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)

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
Reports­
notification
construction/
reconstruction.
40
CFR
63.567(
b)(
4)

Notification
of
anticipated
start
up
40
CFR
63.567(
b)(
2)
and
(
b)(
3)

Notification
of
actual
start
up
63.566,
63.5
Notification
of
applicability
report
63.567(
b)(
1),
63.9
Notification
for
initial
performance
test
date
63.567(
f)
,
63.9
6
Reports
for
Regulatory
Citation
Routine
report
of
performance
testing
(
flares)
63.567(
d),
63.11
Excess
emissions
and
monitoring
performance
and
/
or
summary
report
on
compliance
40
CFR63.567(
e)(
3),
63(
c)
and
(
e)

Report
of
HAP
control
efficiency
"
"
63.567(
b)(
5)

A
source
must
maintain
the
following
records:

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

Emission
test
results
and
other
data
needed
to
determine
emissions
40
CFR
61.13(
g)

All
reports
and
notifications
"
"
63.10(
b)

Records
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
for
40
CFR
63.
X.
60.
X,
61.
X,
63.
X
Record
Keeping
­
emission
estimates
40
CFR
63.565(
l)

"
"
­
initial
performance
test
records
and
engineering
report
"
"
63.567(
f)

"
"
­
performance
records
on
applicable
vents,
valves
and
vapor
collection
systems
"
"
63.567(
g)

"
"
­
vapor
tightness
documentation
"
"
63.567(
h)

"
"
­
marine
vessel
loading
records
"
"
63.567(
i)

"
"
­
emission
estimates,
product
through­
put
and
identification
"
"
63.567(
j)

"
"
­
leak
detection,
repair,
vapor
collection
systems,
and
Control
devices
"
"
63.567(
k)

"
"
­
keep
records
­
5
years
"
"
63.10(
b)(
1)
7
(
ii.)
Respondent
Activities
Respondent
Activities
Read
instructions.

Write
excess
emissions
and
status
reports
as
needed.

Perform
initial
performance
test,
check
performance
of
flares
or
other
equipment.

Write
the
notifications
and
reports
listed
above.

Enter
information
required
to
be
recorded
above.

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

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

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

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

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

Transmit,
or
otherwise
disclose
the
information.

The
rule
does
not
require
use
of
information
collection
techniques
such
as
automated,
mechanical
or
other
technical
collection
techniques.
Electronic
submissions
can
be
made
but
they
must
be
followed
up
with
a
hard
copy
that
is
signed
by
the
owner/
operator
of
the
facility.

5.
The
Information
Collected
­­
Agency
Activities,
Collection
Methodology,
and
Information
Management
5(
a)
Agency
Activities
EPA
conducts
the
following
activities
in
connection
with
the
acquisition,
analysis,
storage,
and
distribution
of
the
required
information.

Agency
Activities
Observe
initial
performance
tests
and
repeat
performance
tests
if
necessary.
8
Agency
Activities
Review
notifications
and
reports,
including
performance
test
reports,
excess
emissions
reports,
and
status
reports
required
to
be
submitted
by
industry.

Audit
facility
records.

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

5(
b)
Collection
Methodology
and
Management
Following
notification
of
start­
up,
the
reviewing
authority
might
inspect
the
source
to
determine
whether
the
pollution
control
devices
are
properly
installed
and
operated.
Performance
reports
on
the
use
of
controls
is
used
by
the
agency
to
estimate
operating
conditions
under
which
compliance
was
achieved.
Data
and
records
maintained
by
the
respondents
are
kept
on
file
for
inspectors
to
examine.
The
semiannual
reports
are
used
only
to
report
problem
identification
and
to
report
problems
in
compliance.
Other
reports
on
an
annual
basis
are
used
for
rule
applicability
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
five
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:
Industry
Burden.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
9
Table
2
documents
the
computation
of
individual
burdens
for
the
recordkeeping
and
reporting
requirements
applicable
to
the
industry
for
the
Subpart
included
in
this
ICR.
The
individual
burdens
are
expressed
under
standardized
headings
believed
to
be
consistent
with
the
concept
of
burden
under
the
Paperwork
Reduction
Act.
Where
appropriate,
specific
tasks
and
major
assumptions
have
been
identified.
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.

6(
a)
Estimating
Respondent
Burden
The
average
annual
burden
to
industry
over
the
next
three
years
from
these
recordkeeping
and
reporting
requirements
is
estimated
at
28,131
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
National
Emissions
Standards
for
Hazardous
Air
Pollutants
program,
the
previously
approved
ICR,
and
any
comments
received.

6(
b)
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.
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%))

The
only
type
of
industry
costs
associated
with
the
information
collection
activity
in
the
standards
are
labor
costs.
There
are
no
capital/
startup
costs.

The
active
ICR
does
not
have
capital/
startup
and
operation
and
maintenance
costs
write
under
14d.
The
current
OMB
inventory
for
this
is
a
cost
of
0.
Equipment,
parts
and
contracted
maintenance
are
not
needed
for
the
industry.
The
industry
has
elected
to
not
install
continuous
monitoring
devises
which
was
an
option
under
the
rule.
The
industry
has
installed
primarily
flares
to
control
emissions.
Hence
the
only
industry
costs
are
the
labor
costs
for
performance
tests,
reporting,
and
keeping
records.
Reporting
has
also
been
kept
to
a
minimum
under
this
rule.
The
industry
can
use
in­
house
staff
to
complete
the
work
needed.

(
iii)
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
10
The
only
type
of
industry
costs
associated
with
the
information
collection
activity
in
the
standards
are
labor
costs.
There
are
no
capital/
startup
costs.

6(
c)
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
$
62,126.
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.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
able
See
the
total
burden
and
costs
listed
in
Table
2.

6(
f)
Reasons
for
Change
in
Burden
The
burden
hours
are
the
same
in
the
renewal
and
the
active
ICR.
Cost
differences
result
only
from
the
increase
in
labor
rates.

6(
g)
Burden
Statement
Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
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
Ms.
Sandy
Farmer,
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,
11
NW,
Washington,
DC
20503,
Attention:
Desk
Officer
for
EPA.
Include
the
EPA
ICR
number
and
OMB
Control
Number
in
any
correspondence.

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