SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
STANDARDS
OF
PERFORMANCE
NSPS
SUBPART
QQQ
PETROLEUM
REFINERY
WASTEWATER
SYSTEMS
1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
ICR
for
NSPS
Subpart
QQQ
­
Standards
of
Performance
for
VOC
Emissions
from
Petroleum
Refinery
Wastewater
Systems
1(
b)
Short
Characterization/
Abstract
The
New
Source
Performance
Standards
(
NSPS)
for
petroleum
refinery
wastewater
systems
were
proposed
on
May
4,
1987
and
promulgated
on
November
23,
1988.
These
standards
apply
to
the
following
facilities
in
petroleum
refinery
wastewater
systems:
individual
drain
systems,
oil­
water
separators,
and
aggregate
facilities
commencing
construction,
modification
or
reconstruction
after
the
date
of
proposal.
An
individual
drain
system
consists
of
all
process
drains
connected
to
the
first
downstream
junction
box.
An
oil­
water
separator
is
the
wastewater
treatment
equipment
used
to
separate
oil
from
water.
An
aggregate
facility
is
an
individual
drain
system
together
with
ancillary
downstream
sewer
lines
and
oil­
water
separators,
down
to
and
including
the
secondary
oil­
water
separators,
as
applicable.
Aggregate
facilities
were
created
to
capture
all
potential
volatile
organic
compound
(
VOC)
emissions
within
the
petroleum
refinery
wastewater
system
even
as
this
system
is
expanded
and
added
to.
There
are
no
additional
recordkeeping
or
reporting
requirements
for
aggregate
facilities.
This
information
is
being
collected
to
assure
compliance
with
40
CFR
Part
60
Subpart
QQQ.

Owners
or
operators
of
the
affected
facilities
described
must
make
initial
notification
and
maintain
records
of
the
occurrence
and
duration
of
any
startup,
shutdown,
or
malfunction
in
the
operation
of
an
affected
facility,
or
any
period
during
which
the
monitoring
system
is
inoperative.
Monitoring
requirements
specific
to
petroleum
refinery
wastewater
systems
provide
information
on
the
operation
of
the
emissions
control
device.
Semiannual
reports
of
excess
emissions
are
required.
These
notifications,
reports
and
records
are
required,
in
general,
of
all
sources
subject
to
NSPS.
Any
owner
or
operator
subject
to
the
provisions
of
this
part
shall
maintain
a
file
of
these
measurements,
maintenance
reports
and
records
and
retain
the
file
for
at
least
two
years
following
the
date
of
such
measurements,
maintenance
reports,
and
records.

Approximately
160
sources
are
currently
subject
to
the
standard
(
respondent),
and
it
is
estimated
that
no
additional
sources
will
become
subject
to
the
standard
in
the
next
three
years.
It
is
further
assumed
that
there
is
an
average
of
two
affected
facilities
per
plant.
The
annual
cost
of
this
ICR
will
be
56,000
dollars
for
nonlabor,
and
2,025,418
dollars
for
labor
for
a
total
of
2,081,418
dollars.
2
These
estimates
are
based
on
AIRS
data
and
TRI
data.
The
number
of
refineries
has
remained
constant
since
the
previous
approval
and
this
trend
is
expected
to
continue.
The
last
ICR
submittal
for
this
source
speculated
that
one
new
source
would
be
added
per
year.
The
numbers
have
shown
that
this
was
an
over­
estimation.
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
111
of
the
Clean
Air
Act,
as
amended,
to
establish
standards
of
performance
for
new
stationary
sources
that
reflect:
.
.
.
application
of
the
best
technological
system
of
continuous
emissions
reduction
which
(
taking
into
consideration
the
cost
of
achieving
such
emissions
reduction,
or
any
non­
air
quality
health
and
environmental
impact
and
energy
requirements)
the
Administrator
determines
has
been
adequately
demonstrated
[
Section
111(
a)(
l)].

The
Agency
refers
to
this
charge
as
selecting
the
best
demonstrated
technology
(
BDT).
Section
111
also
requires
that
the
Administrator
review
and,
if
appropriate,
revise
such
standards
every
four
years.

In
addition,
Section
114(
a)
states
that:

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),
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
compliance
certifications,
and
(
G)
provide
such
other
information
as
he
may
reasonably
require.

In
the
Administrator's
judgement,
VOC
emissions
from
petroleum
refinery
wastewater
systems
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
New
Source
Performance
Standards
were
promulgated
for
this
source
category
at
40
CFR
Part
60,
Subpart
QQQ
­
Standards
of
Performance
for
VOC
Emissions
from
Petroleum
Refinery
Wastewater
Systems.

2(
b)
Practical
Utility/
Users
of
the
Data
The
control
of
emissions
of
Volatile
Organic
Compounds
(
VOC)
from
petroleum
refinery
3
wastewater
systems
requires
not
only
the
installation
of
properly
designed
equipment,
but
also
the
operation
and
maintenance
of
that
equipment.
Emissions
of
VOC
from
petroleum
refinery
wastewater
systems
are
the
result
of
operation
of
the
individual
drain
systems
and
the
oil­
water
separators.
These
standards
rely
on
the
capture
and
reduction
of
VOC
emissions
by
use
of
flares
and
carbon
adsorbers,
and
by
a
leak
detection
and
repair
(
LDAR)
program.
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
when
flares
are
used
as
a
control
device
as
these
are
the
Agency's
record
of
a
source's
initial
capability
to
comply
with
the
emission
standard,
and
note
the
operating
conditions
(
proper
heat
and
retention
time)
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
monitoring,
recordkeeping
and
reporting
requirements
described
in
this
ICR
is
used
by
the
Agency
to
ensure
that
facilities
affected
by
the
NSPS
continue
to
operate
the
control
equipment
and
implement
the
LDAR
program
used
to
achieve
compliance
with
the
NSPS.
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
3(
a)
Nonduplication
The
recordkeeping
and
reporting
requested
is
required
under
40
CFR
Part
60
Subpart
QQQ.
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
NSPS
Subpart
QQQ,
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
April
18,
2000
(
65
FR
20813).

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

3(
d)
Effects
of
Less
Frequent
Collection
4
If
the
information
required
by
these
standards
was
collected
less
frequently,
the
main
consequence
would
be
that
the
chances
of
detecting
poor
operation
and
maintenance
of
control
equipment
would
decrease.
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.

3(
e)
General
Guidelines
None
of
the
reporting
or
recordkeeping
requirements
contained
in
40
CFR
Part
60
or
otherwise
pertinent
to
this
request
violate
any
of
the
regulations
established
by
OMB
in
5
CFR
1320.6.

3(
f)
Confidentiality
The
required
information
consists
of
emissions
data
and
other
information
that
have
been
determined
not
to
be
private.
However,
any
information
submitted
to
the
Agency
for
which
a
claim
of
confidentiality
is
made
will
be
safeguarded
according
to
the
Agency
policies
set
forth
in
Title
40,
Chapter
1,
Part
2,
Subpart
B
­
Confidentiality
of
Business
Information
(
see
40
CFR
2;
41
FR
36902,
September
1,
1976;
amended
by
43
FR
40000,
September
8,
1978;
43
FR
42251,
September
20,
1978;
44
FR
17674,
March
23,
1979).

3(
g)
Sensitive
Questions
None
of
the
reporting
or
recordkeeping
requirements
contained
in
40
CFR
Part
60
or
otherwise
pertinent
to
this
request
contain
sensitive
questions.

4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
SIC
Codes
The
respondents
of
the
recordkeeping
and
reporting
requirements
are
petroleum
refinery
wastewater
systems
(
SIC
Code
2911)
that
commenced
construction,
modification,
or
reconstruction
after
May
4,
1987.

4(
b)
Information
Requested
(
A)
Data
Items
All
data
in
this
ICR
that
is
recorded
and
reported
is
required
by
40
CFR
Part
60,
Subpart
QQQ
­
Standards
of
Performance
for
VOC
Emissions
from
Petroleum
Refinery
Wastewater
Systems.
5
Provide
notification
of
­
construction/
reconstruction
(
60.7(
a)(
1))
­
modification
(
60.7(
a)(
4)
­
anticipated
startup
(
60.7(
a)(
2)
­
actual
startup
(
60.7(
a)(
3)
­
initial
performance
test
(
60.8(
a))
­
election
to
construct
and
operate
a
completely
closed
drain
system
(
60.693­
1(
c),
60.698(
a))
­
election
to
construct
and
operate
a
floating
roof
on
an
oil­
water
separator
(
60.693­
2(
b),
60.698(
a))
­
intent
to
use
an
alternative
means
of
emission
limitation
(
60.694(
c))
­
intent
to
use
a
VOC
control
device
other
than
a
carbon
adsorber
to
meet
the
requirements
of
60.692­
5(
a),
with
information
describing
the
control
device
and
the
process
parameters
being
monitored
(
60.695(
b))
­
demonstration
that
alternative
operational
or
process
parameter
will
ensure
control
device
is
operated
in
compliance
with
standards
(
60.695(
c))
­
anticipated
and
actual
startup,
including
certification
that
requirements
for
equipment
and
inspections
have
been
met
(
60.698(
b)(
1))
­
notification
of
delay
in
compliance
along
with
the
date
of
the
next
scheduled
refinery
or
process
unit
shutdown
and
reasons
why
delay
is
necessary
(
60.698(
e))

Report
on
­
initial
performance
test
data
and
result
for
flares
(
60.8
(
a),
60.698(
b)(
2))
­
initial
and
semiannual
inspection
reports
(
60.698(
c))
­
semiannual
reports
on
control
device
performance
(
60.698(
d))

Record
­
startups,
shutdowns,
malfunctions,
periods
where
the
continuous
monitoring
system
is
inoperative
(
60.7(
b))
­
location,
date,
and
corrective
actions
for
process
drains
not
in
compliance
(
60.697(
b)(
1))
­
location,
date,
and
corrective
actions
for
junction
boxes
out
of
compliance
(
60.697(
b)(
2))
­
location,
date,
and
corrective
actions
for
sewer
lines
out
of
compliance
(
60.697(
b)(
3))
­
location,
date,
and
corrective
actions
for
oil­
water
separators
out
of
compliance
(
60.697(
c))
­
location,
date,
and
corrective
actions
for
closed­
vent
systems
out
of
compliance
(
60.697(
d))
6
­
expected
date
of
repairs
if
emission
point
cannot
be
repaired,
reason
for
delay,
signature
of
company
official
who
authorizes
the
delay,
and
the
date
of
actual
repairs
(
60.697(
c))
­
copy
of
design
specifications
for
all
equipment
used
to
comply
with
the
standards
(
60.697(
f)(
1)
and
(
2)
­
information
pertaining
to
the
operation
and
maintenance
of
closed­
drain
systems
and
closed­
vent
systems
(
60.697(
f)(
3)
­
location
and
plans
or
specifications
for
inactive
process
drains
(
60.697(
g))
­
location
and
plans
or
specifications
for
exempted
stormwater
sewer
systems
(
60.697(
h))
­
location
and
plans
or
specifications
for
exempted
ancillary
equipment
(
60.697(
i))
­
location
and
plans
or
specifications
for
exempted
non­
contact
cooling
water
systems
(
60.697(
j))

Monitoring
and
Inspections
­
of
operation
of
control
devices
(
60.18(
f),
60.695)
­
of
affected
facilities
(
60.18(
f),
60.692­
2,
60.692­
3,
60.692­
4,
60.692­
5,
60.693­
1,
60.693­
2)

Records
are
required
to
be
retained
for
two
years.

(
B)
Respondent
Activities
­
read
instructions
­
perform
initial
performance
test
(
Reference
Method
22
test)
and
repeat
performance
tests
­
write
the
notifications
and
reports
listed
above
­
enter
information
required
to
be
recorded
above
­
submit
the
required
reports
developing,
acquiring,
installing,
and
utilizing
technology
and
systems
for
the
purpose
of
collecting,
validating,
and
verifying
information
­
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purpose
of
processing
and
maintaining
information
­
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
5.
The
Information
Collected
­­
Agency
Activities,
Collection
Methodology,
and
Information
Management
7
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
QQQ:
­
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
for
a
flare
control
device
to
discern
a
source's
initial
capability
to
comply
with
the
emission
standard
and
note
the
operating
conditions
(
proper
heat
and
retention
time)
under
which
compliance
was
achieved.
Data
obtained
during
periodic
visits
by
Agency
personnel
from
records
maintained
by
the
respondents
are
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.
The
records
required
by
this
NSPS
must
be
retained
by
the
owner
or
operator
for
(
two)
years.

5(
c)
Small
Entity
Flexibility
The
recordkeeping
and
reporting
requirements
were
selected
within
the
context
of
a
small
collection
of
process
equipment
and
reflect
the
burden
on
small
businesses.
To
the
extent
that
larger
businesses
can
use
economies
of
scale
to
reduce
their
burden,
the
overall
burden
will
be
reduced.
However,
even
though
the
recordkeeping
and
reporting
requirements
are
the
same
for
small
and
larger
businesses,
the
Agency
considers
these
requirements
the
minimum
needed
to
ensure
compliance,
and
therefore,
it
cannot
reduce
them
further
for
small
businesses.

5(
d)
Collection
Schedule
The
specific
frequency
for
each
information
collection
activity
within
this
request
is
shown
8
on
Tables
2
and
3
of
Appendix
A.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
Tables
2
and
3
document
the
computation
of
individual
burdens
for
each
of
the
recordkeeping
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
(
40
CFR
60.697
and
60.698).
The
Agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.

6(
a)
Estimating
Respondent
Burden
The
average
annual
burden
to
industry
over
the
next
three
years
from
these
recordkeeping
and
reporting
requirements
is
estimated
at
36,866
person­
hours
(
total
from
industry
table
3).
These
hours
are
based
on
Agency
studies
and
background
documents
from
the
development
of
the
standards
or
test
methods,
Agency
knowledge
and
experience
with
the
NSPS
program,
the
previously
approved
ICR,
and
any
comments
received
about
time
to
prepare
reports.

6(
b)
Estimating
Respondent
Costs
(
A)
Estimating
Labor
Costs
This
ICR
uses
labor
rates
of
$
54.94
($
26.16
plus
110%
overhead)
from
the
United
States
Department
of
Commerce
Bureau
of
Labor
Statistics,
Table
2:
Employment
Costs
for
Civilian
Workers
by
Occupational
and
Industry
Group.
The
recordkeeping
and
reporting
requirements
for
this
standard
do
not
involve
the
use
of
clerical
or
managerial
hours.
The
average
annual
burden
to
industry
over
the
next
three
years
from
these
recordkeeping
and
reporting
requirements
is
estimated
at
36,866
person­
hours.
The
average
annual
burden
to
industry
over
the
next
three
years
of
the
ICR
is
estimated
to
be
$
2,025,418.

(
B)
Estimating
Capital
and
Operations
and
Maintenance
Costs
The
type
of
industry
costs
associated
with
the
information
collection
activity
in
the
standards
are
labor
costs
and
continuous
emissions
monitoring
for
flares.
The
capital
start
up
costs
are
one
time
costs
when
a
facility
becomes
subject
to
the
standard.
The
capital
start
up
costs
for
this
regulation
are
$
760.
This
is
based
on
one
new
source
per
year.
The
annual
operations
and
maintenance
costs
are
$
56,000.
This
is
based
on
160
existing
sources
multiplied
by
$
350
for
upkeep
of
the
monitoring
device.
The
total
respondent
costs
have
been
calculated
on
the
addition
of
the
capital
start
up
costs
and
the
annual
operations
and
maintenance
costs.
The
average
annual
burden
for
capital
and,
operations
and
maintenance
costs
to
industry
over
the
next
9
three
years
of
the
ICR
is
estimated
to
be
$
56,000.

(
C)
Capital/
Start­
up
vs.
Operating
and
Maintenance
(
O&
M)
Costs
Monitoring
device
Start­
up
cost
($)
Annual
O&
M
costs
($)

Flare
760
56,000
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
the
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
3
years
of
the
ICR
is
estimated
to
be
93,960
dollars.
This
cost
is
based
on
an
average
wage
of
a
GS10
step
1
employee
rate
and
travel
associated
with
compliance
activities.
Details
upon
which
this
estimate
is
based
appear
in
Table
1:
Federal
Burden.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
The
number
of
existing
sources
subject
to
40
CFR
Part
60.690,
Subpart
QQQ
is
160.
The
number
of
new
sources
subject
to
40
CFR
Part
60.690,
Subpart
QQQ
is
none.
The
total
annual
labor
burden
is
36,866
hours.
The
total
annual
labor
costs
are
$
2,025,418
and
total
annual
capital
and
O&
M
costs
to
the
regulated
entity
are
56,000
dollars.
Details
upon
which
this
estimate
is
based
appear
in
Tables
2
and
3:
Industry
Burden.

6(
e)
Bottom
Line
Burden
Hours
And
Cost
Tables
See
Tables
2
and
3
in
Appendix
A.

6(
f)
Reasons
for
Change
in
Burden
The
increase
in
burden
from
the
last
ICR
submittal
is
due
to
the
increase
in
labor
rate
from
the
last
submittal.

6(
g)
Burden
Statement
Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
10
and
systems
to
collect,
validate,
and
verify
information,
process
and
maintain
information,
and
disclose
and
provide
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
Sandy
Farmer,
U.
S.
Environmental
Protection
Agency,
Collection
Strategies
Division
(
Mail
Code
2822),
1200
Pennsylvania
Avenue,
N.
W.,
Washington,
DC
20460;
and
to
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget
(
OMB),
Attention:
Desk
Officer
for
EPA,
725
17th
Street,
N.
W.,
Washington,
DC
20503.
Include
the
EPA
ICR
number
1136.06
and
OMB
control
number
2060­
0172
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
Appendix
A
1.
$
17.09
per
hour
plus
110%
overhead
=
$
35.89
per
hour.

2.
One
facility
subject
to
performance
test
each
year;
EPA
witnesses
8%
of
tests,
for
average
of
0.08
tests
per
year.
0.08
tests
per
year
at
120
hours
per
test
averages
to
9.6
(
or
10
hours)
per
year
witnessing
performance
tests.
TABLE
1:
ESTIMATE
OF
AVERAGE
ANNUAL
DIRECT
PERSONNEL
COST
TO
THE
FEDERAL
GOVERNMENT
Activity
EPA
Hrs/
Occurrences
(
A)
Occurrences/
Facility/
Year
(
B)
EPA
Hrs/
Facilities/
Yr
(
C)
Facilities
/
Yr
(
D)
EPA
Hrs/
Yr
(
E)
EPA
Cost
$
1
(
F)

1.
Review
of
notification
of
construction/
reconstruction
2
1
2
1
2
72
2.
Review
of
notification
of
anticipated
startup
2
1
2
1
2
72
3.
Review
of
notification
of
actual
start­
up
2
1
2
1
2
72
4.
Review
of
design
specifications
and
complete
reports
8
1
8
1
8
287
5.
Review
of
notification
of
initial
performance
test
2
1
2
1
2
72
6.
Review
of
performance
test
report
8
1
8
1
8
287
7.
Attend
performance
test
2
120
1
120
0.08
10
359
TABLE
1
(
Continued):
ESTIMATE
OF
AVERAGE
ANNUAL
DIRECT
PERSONNEL
COST
TO
THE
FEDERAL
GOVERNMENT
Activity
EPA
Hrs/
Occurrence
(
A)
Occurrences/
Plant/
Year
(
B)
EPA
Hrs/
Facility/
Yr
(
C)
Facilities
/
Yr
(
D)
EPA
Hrs/
Yr
(
E)
EPA
Cost
$
1
(
F)

8.
Attend
performance
retests
3
See
footer
#
3
24
861
9.
Review
of
semiannual
reports
8
2
16
160
2560
91,87
8
Subtotal
2,602
93,96
0
1.
$
17.09
per
hour
plus
110%
overhead
=
$
35.89
per
hour.

3.
Assuming
20%
of
the
1
facilit(
y)
s
tested
per
year
fail,
an
annual
average
of
0.2
facilities
would
fail
the
performance
test.
50%
of
the
facilities
that
fail
would
require
retesting
(
0.1).
Retesting
preparation
requires
16
person­
hours
of
Agency
time
for
a
notice
and
a
conference
(
1.6
hours
per
year).
If
EPA
witnesses
0.3
retest
every
3
years
(
10%
of
retest),
EPA
would
witness
0.09
retests
per
year.
At
120
hours
per
retest
EPA
would
expend
an
average
of
12
person­
hours
witnessing
retests;
compliance
order
preparation
would
require
40
hours
for
each
of
the
0.09
test
per
year,
or
3.6
person­
hours
per
year;
delay
in
testing
for
the
10%
of
the
0.09
tests
witnessed
by
EPA
would
require
1.2
hours.
The
total
person­
hours
expended
for
attending
performance
retests
would
be
1.6
(
preparation)
plus
1.2
(
retesting)
plus
3.6
(
preparing
orders)
plus
1.2
(
witnessing
delayed
retests)
equals
7.6
hours
per
year.
(
Which
is
rounded
to
8
hours
per
year)
1.
Assume
that
100%
of
industry
sources
use
process
drain
systems.

2.
Assume
an
hourly
wage
of
$
26.16
plus
110%
overhead
costs
which
equals
$
54.94.
This
amount
was
multiplied
by
the
hours
per
year
in
column
E.
TABLE
2:
BURDEN
TO
INDUSTRY
CALCULATIONS
FOR
PETROLEUM
REFINERY
WASTEWATER
SYSTEMS
(
PROCESS
DRAIN
SYSTEMS)
1
Burden
Item
Hours/
Occurrenc
e
(
A)
Occurrences/
Respondents/
Year
(
B)
Hours/
Respondent/
Year
(
C)
Respondents/
Year
(
D)
Hours/
Year
(
E
=
C
x
D)
Cost/
Year
2
$

(
F)

1.
Applications
Not
Applicable
2.
Survey
and
Studies
Not
Applicable
3.
Reporting
Requirements
A.
Read
Instructions
1
1
1
1
1
55
B.
Required
Activities
1.
Inspect
drain
systems
2
12
24
160
3,840
210,970
C.
Create
Information
See
3B.

D.
Gather
Existing
Information
See
3E.

E.
Write
Report
1)
Notification
of
construction/
reconstruction
2
1
2
1
2
110
2)
Notification
of
anticipated
startup
2
1
2
1
2
110
3)
Notification
of
actual
start­
up
2
1
2
1
2
110
4)
Design
specifications
and
compliance
certifications
Not
Applicable
5)
Semiannual
report
8
2
16
160
2,560
140,646
4.
RECORD
KEEPING
RQMNTS
A.
Read
instructions
See
3A.
1.
Assume
that
100%
of
industry
sources
use
process
drain
systems.

2.
Assume
an
hourly
wage
of
$
26.16
plus
110%
overhead
costs
which
equals
$
54.94.
This
amount
was
multiplied
by
the
hours
per
year
in
column
E.
B.
Plan
activities
Not
Applicable
TABLE
2
(
Continued):
BURDEN
TO
INDUSTRY
CALCULATIONS
FOR
PETROLEUM
REFINERY
WASTEWATER
SYSTEMS
(
PROCESS
DRAIN
SYSTEMS)
1
Burden
Item
Hours/
Occurrenc
e
(
A)
Occurrences/
Respondents/
Year
(
B)
Hours/
Respondent/
Year
(
C)
Respondents/
Year
(
D)
Hours/
Year
(
E
=
C
x
D)
Cost/
Year
2
$

(
F)

4.
RECORD
KEEPING
RQMNTS
C.
Implement
activities
Not
Applicable
D.
Develop
record
system
Not
Applicable
E.
Time
to
enter
information
1.5
52
78
160
12,480
685,651
F.
Time
to
train
personnel
Not
Applicable
G.
Time
for
audits
Not
Applicable
5.
TOTAL:
All
Burden
Items
18,887
1,037,652
1.
Assume
that
100%
of
industry
sources
use
oil­
water
separators.
2.
Assume
an
hourly
wage
of
$
26.16
plus
110%
overhead
costs
which
equals
$
54.94.
This
amount
was
multiplied
by
the
hours
per
year
in
column
E.
3.
Assume
that
50%
of
oil­
water
separators
use
a
flare
device
to
control
VOC
emissions.
The
remainder
use
alternative
vapor
control
devices
that
are
not
subject
to
performance
test
requirements.
TABLE
3:
BURDEN
TO
INDUSTRY
CALCULATIONS
FOR
PETROLEUM
REFINERY
WASTEWATER
SYSTEMS
(
OIL­
WATER
SEPARATORS)
1
AND
INDUSTRY
BURDEN
TOTALS
Burden
Item
Hours/
Occurrences
(
A)
Occurrences/
Respondent/
Year
(
B)
Hours/
Respondent/
Year
(
C
=
A
x
B)
Respondents/
Year
(
D)
Hours/
Year
(
E
=
C
x
D)
Cost/
Year
2
$

(
F)

1.
Applications
Not
Applicable
2.
SURVEY
AND
STUDIES
Not
Applicable
3.
REPORTING
RQMNTS
A.
Read
Instructions
1
1
1
1
1
55
B.
Required
Activities
1)
Semiannual
inspection
8
2
16
160
2,560
140,646
2)
Performance
Test
3
330
1
330
1
330
18,130
C.
Create
Information
See
3B.

D.
Gather
Existing
Information
See
3E.

E.
Write
Report
1)
Notification
of
construction/
reconstruction
2
1
2
1
2
110
2)
Notification
of
anticipated
start­
up
2
1
2
1
2
110
3)
Notification
of
actual
startup
2
1
2
1
2
110
1.
Assume
that
100%
of
industry
sources
use
oil­
water
separators.
2.
Assume
an
hourly
wage
of
$
26.16
plus
110%
overhead
costs
which
equals
$
54.94.
This
amount
was
multiplied
by
the
hours
per
year
in
column
E.
3.
Assume
that
50%
of
oil­
water
separators
use
a
flare
device
to
control
VOC
emissions.
The
remainder
use
alternative
vapor
control
devices
that
are
not
subject
to
performance
test
requirements.
TABLE
3
(
Continued):
BURDEN
TO
INDUSTRY
CALCULATIONS
FOR
PETROLEUM
REFINERY
WASTEWATER
SYSTEMS
(
OILWATER
SEPARATORS)
1
AND
INDUSTRY
BURDEN
TOTALS
Burden
Item
Hours/
Occurrences
(
A)
Occurrences/
Respondent/
Year
(
B)
Hours/
Respondent/
Year
(
C
=
A
x
B)
Respondents/
Year
(
D)
Hours/
Year
(
E
=
C
x
D)
Cost/
Year
2
$

(
F)

4)
Design
specifications
and
compliance
certifications
40
1
40
1
40
2,198
5)
Semiannual
report
8
2
16
160
2,560
140,646
E.
Write
Report
6)
Notification
of
performance
test
2
1
2
1
2
110
7)
Results
of
performance
test
See
3B.

4.
RECORD
KEEPING
RQMNTS
A.
Read
instructions
See
3A.

B.
Plan
activities
Not
Applicable
C.
Implement
activities
Not
Applicable
D.
Develop
record
system
Not
Applicable
E.
Time
to
enter
information
1.5
52
78
160
12,480
685,651
F.
Time
to
train
personnel
Not
Applicable
G.
Time
for
audits
Not
Applicable
5.
TOTAL:
All
Burden
Items
17,979
987,766
1.
Assume
that
100%
of
industry
sources
use
oil­
water
separators.
2.
Assume
an
hourly
wage
of
$
26.16
plus
110%
overhead
costs
which
equals
$
54.94.
This
amount
was
multiplied
by
the
hours
per
year
in
column
E.
3.
Assume
that
50%
of
oil­
water
separators
use
a
flare
device
to
control
VOC
emissions.
The
remainder
use
alternative
vapor
control
devices
that
are
not
subject
to
performance
test
requirements.
TABLE
3
(
Continued):
BURDEN
TO
INDUSTRY
CALCULATIONS
FOR
PETROLEUM
REFINERY
WASTEWATER
SYSTEMS
(
OILWATER
SEPARATORS)
1
AND
INDUSTRY
BURDEN
TOTALS
Burden
Item
Hours/
Occurrences
(
A)
Occurrences/
Respondent/
Year
(
B)
Hours/
Respondent/
Year
(
C
=
A
x
B)
Respondents/
Year
(
D)
Hours/
Year
(
E
=
C
x
D)
Cost/
Year
2
$

(
F)

TOTAL
BURDEN
Table
1
plus
Table
2
36,866
$
2,025,418
