SUPPORTING
STATEMENT
FOR
THE
CONSOLIDATION
OF
INFORMATION
COLLECTION
REQUESTS
(
ICRs)
FOR
THE
SYNTHETIC
ORGANIC
CHEMICAL
MANUFACTURING
INDUSTRY
(
SOCMI)

EPA
ICR
NUMBER
1854.03
April
2002
2
TABLES
AND
ATTACHMENTS
TABLE
PAGE
1
Persons
Consulted
in
the
CAR
Rule
Making
Effort
25
2
Agency
Activities
26
3
Annual
Burden
and
Cost
to
the
Federal
Government
for
CAR
Provisions
27
4
Estimated
Number
of
Sources
Subject
to
Referencing
Subparts
That
Will
Opt
to
Comply
with
the
CAR
28
5
Annual
Respondent
Technical
Burden
Hours
of
Reporting
and
Record
Keeping
for
the
CAR
29
6
Existing
Source
Annual
Respondent
Burden
and
Cost
of
Reporting
and
Recordkeeping
Requirements
for
the
CAR
31
7
Summary
of
EPA
and
Respondent
Burden
and
Cost
for
Referencing
Subparts
and
the
CAR
32
ATTACHMENT
PAGE
A
Record
Keeping
and
Reporting
under
the
CAR
A­
1
C
Assumptions
and
Item
Descriptions
for
Table
3
C­
1
E
Assumptions
and
Item
Descriptions
for
Table
6
E­
1
F
EPA
Burden
and
Cost
for
Referencing
Subparts
F1
to
F10
F­
1
G
Respondent
Burden
and
Cost
for
Referencing
Subparts,
G­
1
to
G­
12
G­
1
H
Assumptions
and
Item
Descriptions
for
Attachment
F:
Table
F.
11
H­
1
I
Assumptions
and
Item
Descriptions
for
Attachment
G:
Tables
G.
11
and
G.
12
I­
1
J1
Annual
Cost
Burden
of
Reporting
and
Record
Keeping
Requirements
as
a
Result
of
Subpart
VV,
the
HON,
and
the
CAR
J­
1
J2
Annual
Labor
Costs
for
Contracting
LDAR
Program
(
Subpart
H
and
I)
J­
2
J3
Summary
of
Capital/
Startup
and
O&
M
Costs
for
the
CAR
and
the
Referencing
3
Subparts
J­
3
4
PART
A
OF
THE
SUPPORTING
STATEMENT
1.
Identification
of
the
Information
Collection
(
a)
Title
of
the
Information
Collection
Consolidation
of
Information
Collection
Requests
(
ICRs)
for
the
Synthetic
Organic
Chemical
Manufacturing
Industry
(
SOCMI)

(
b)
Short
Characterization/
Abstract
This
information
collection
request
(
ICR)
is
for
the
consolidation
of
the
Consolidated
Federal
Air
Rule
(
CAR),
and
its
referencing
subparts
into
one
ICR.
The
information
is
being
collected
for
EPA's
Office
of
Air
Quality
Planning
and
Standards
(
OAQPS).
The
information
concerns
the
applicability
of
and
compliance
with
the
provisions
of
the
CAR
and
its
referencing
subparts
and
can
be
submitted
either
in
electronic
or
paper
format.
EPA
will
use
this
information
to
ensure
compliance
with
the
provisions
in
the
CAR
and
its
referencing
subparts.

On
December
14,
2000,
the
CAR
for
the
Synthetic
Organic
Chemical
Manufacturing
Industry
(
SOCMI)
was
promulgated
under
40
CFR
Part
65.
The
CAR
is
an
optional
alternative
compliance
approach
for
plant
sites
that
must
comply
with
existing
subparts
in
the
Code
of
Federal
Regulations
(
CFR).
The
CAR
is
a
consolidation
of
major
portions
of
14
different
New
Source
Performance
Standards
(
NSPS)
and
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
pertaining
to
storage
vessels,
process
vents,
transfer
racks,
equipment
leaks,
and
the
general
provisions
for
the
three
applicable
parts
(
40
CFR
Parts
60,
61,
and
63).

These
subparts
from
40
CFR
Parts
60,
61,
and
63
are
referred
to
as
"
referencing
subparts"

because
they
have
been
amended
to
refer
to
the
CAR
as
a
compliance
alternative.
The
referencing
subparts
include
40
CFR
Part
60,
Subpart
Ka;
40
CFR
Part
60,
Subpart
Kb;
40
CFR
Part
60,
Subpart
VV;
40
CFR
Part
60,
Subpart
DDD;
40
CFR
Part
60,
Subpart
III;
40
CFR
Part
60,
Subpart
NNN;
40
CFR
Part
60,
Subpart
RRR;
40
CFR
Part
61,
Subpart
BB;
40
CFR
Part
61,
Subpart
Y;
40
CFR
Part
61,
Subpart
V;
40
CFR
Part
63,
Subpart
F;
40
CFR
Part
63,

Subpart
G;
40
CFR
Part
63,
Subpart
H;
and
40
CFR
Part
63,
Subpart
I.
1
Subpart
BB
is
currently
under
review
at
OMB.

2
The
currently
approved
ICR
also
includes
36
Subpart
L
sources
with
a
burden
of
7083
hours,
which
will
remain
with
EPA
ICR
Series
Number
1080.

5
Compliance
with
the
CAR
is
a
voluntary
alternative;
sources
may
continue
to
comply
with
existing
applicable
rules
or
may
choose
to
comply
with
the
consolidated
rule.
When
preparing
renewals
for
the
CAR,
or
the
referencing
subparts,
estimates
are
made
of
the
percentage
of
existing
sources
that
will
opt
to
comply
with
the
CAR
in
lieu
of
the
referencing
subparts.
It
is
assumed
that
all
new
sources
will
initially
comply
with
the
appropriate
referencing
subpart.

The
purpose
of
this
revised
ICR
is
to
create
a
consolidated
ICR,
which
will
consist
of
the
CAR
and
its
referencing
subparts.
The
revised
ICR
is
simply
the
sum
of
all
of
the
burden
hours
for
the
CAR
and
its
referencing
subparts
using
the
burden
estimates
for
the
most
recently
approved
collections
for
the
ICRs.
The
referencing
subparts
will
be
renewed
concurrently
with
the
CAR.
As
an
outcome
of
the
consolidation,
the
ICRs
for
the
referencing
subparts
will
be
removed
from
the
Agency's
database,
with
the
exception
of
EPA
Series
Number
1080.
This
ICR
includes
36
Subpart
L
sources
with
a
burden
of
7083
hours,
which
will
remain
with
EPA
ICR
Series
Number
1080,
since
they
are
not
part
of
the
consolidation
effort.
The
burden
estimates
provided
herein
represent
the
most
recently
approved
collections
for
the
following
ICRs:

Referencing
Subpart
EPA
Series
Number
OMB
Control
Number
NSPS
Ka
1050
2060­
0121
NSPS
Kb
1132
2060­
0074
NSPS
VV
662
2060­
0012
NSPS
DDD
1150
2060­
0145
NSPS
III/
NNN
998
2060­
0197
NSPS
RRR
1178
2060­
0269
NESHAP
BB1
1154
2060­
0182
NESHAP
Y2
1080
2060­
0185
NESHAP
V
1153
2060­
0068
6
HON
(
Subparts
F,
G,
H
and
I)
1414
2060­
0282
CAR
1854
2060­
0443
No
changes
were
made
to
the
underlying
assumptions
in
the
individual
ICRs.
The
only
exceptions
to
this
are
where
errors
were
discovered
in
a
table,
text
or
corresponding
83­
I
form
of
the
most
recently
approved
ICR.
Additionally,
the
method
of
calculating
the
total
number
of
annual
responses
for
Block
13b
was
standardized
which
resulted
in
changes
for
certain
ICRs.

Finally,
the
costs
associated
with
contracting
out
leak
detection
and
repair
services
were
moved
from
the
Operation
and
Maintenance
(
O&
M)
section
of
the
CAR
to
the
burden
hour
section
of
the
CAR,
consistent
with
guidance
received
from
the
Office
of
Management
and
Budget
(
OMB)

during
the
2001
Hazardous
Organic
NESHAP
(
HON)
renewal.
This
resulted
in
a
change
to
burden
hours
and
O&
M
costs.
All
changes
made
are
described
in
Section
6(
f).

It
is
estimated
that
the
consolidated
collection
will
involve
3862
respondents
with
10,361
annual
responses
and
cost
a
total
of
$
121,333,635.
The
total
burden
is
estimated
to
be
2,165,600
hours
per
year.
Total
capital
costs
will
be
$
4,273,000
per
year
and
total
capital
and
O&
M
costs
will
be
$
99,921,000
per
year.

The
CAR
(
Consolidated
Air
Rule)

In
general,
the
NSPS,
NESHAP,
CAR
and
MACT
regulations
require
initial
notifications
including
one­
time
notifications
of
initial
startup,
applicability,
initial
compliance
status,

performance
tests,
periodic
monitoring,
recordkeeping,
and
reporting.
Periodic
reports
are
required
semiannually,
and
a
startup,
shutdown,
and
malfunction
plan
must
be
submitted
and
updated
as
needed.
In
addition,
respondents
taking
advantage
of
various
provisions
for
waivers,

approval
of
alternative
methods,
and
changes
in
submittal
schedules
would
be
required
to
submit
requests
or
applications.
This
information
is
being
collected
to
assure
compliance
with
40
CFR
Part
65.

NSPS
Subpart
Ka:
Storage
Vessels
for
Petroleum
Liquids
The
New
Source
Performance
Standards
(
NSPS)
for
Subpart
Ka
were
proposed
on
7
May
18,
1978,
and
promulgated
on
April
4,
1980.
These
standards
apply
to
the
following
facilities
in
Subpart
Ka:
storage
vessels
of
petroleum
liquids
that
have
a
storage
capacity
greater
than
151,416
(
40,000
gallons),
and
for
which
construction,
reconstruction
or
modification
commenced
after
May
18,
1978
and
prior
to
July
23,
1984.
There
is
a
de
minimis
exemption
located
at
40
CFR,
Section
60.110a(
b).
The
regulated
pollutants
are
volatile
organic
compounds
(
VOC).
The
universe
of
sources
subject
to
NSPS
Subpart
Ka
is
closed.
Any
new
sources
will
be
subject
to
NSPS
Subpart
Kb,
the
most
recent
VOC
standard
applicable
to
storage
vessels.
This
information
is
being
collected
to
assure
compliance
with
40
CFR
Part
60,
Subpart
Ka.

NSPS
Subpart
Kb:
Volatile
Organic
Liquid
(
VOL)
Storage
Vessels
The
New
Source
Performance
Standards
(
NSPS)
for
Subpart
Kb
were
proposed
on
July
23,
1984,
and
promulgated
on
April
8,
1987.
These
standards
apply
to
each
storage
vessel
with
a
capacity
greater
than
or
equal
to
40
cubic
meters
that
is
used
to
store
volatile
organic
liquids
(
VOL),
for
which
construction,
reconstruction
or
modification
commenced
after
July
23,

1984.
There
are
exemptions
for
specific
storage
vessels
listed
in
40
CFR,
Sections
60.110b(
b),

60.110b(
c),
and
60.110b(
d).
The
standards
include
visual
inspection,
leak
detection,
and
repair
for
equipment
configurations
including
fixed
and
floating
roofs.
The
regulated
pollutant
is
VOC.

This
information
is
being
collected
to
assure
compliance
with
40
CFR
Part
60,
Subpart
Kb.

NSPS
Subpart
VV:
Equipment
Leaks
of
Volatile
Organic
Compounds
(
VOC)
in
the
SOCMI
Industry
The
New
Source
Performance
Standards
(
NSPS)
for
Emissions
of
Volatile
Organic
Compounds
(
VOC)
from
Equipment
Leaks
in
the
Synthetic
Organic
Chemicals
Manufacturing
Industry
(
SOCMI)
were
proposed
on
January
5,
1981.
These
standards
were
promulgated
on
October
18,
1983.
They
apply
to
specific
pieces
of
equipment
contained
within
a
process
unit
in
the
synthetic
organic
chemicals
manufacturing
industry
which
were
constructed,
modified
or
reconstructed
after
the
date
of
proposal,
and
which
produce
as
an
intermediate
or
final
product,

one
or
more
of
the
chemicals
listed
in
Section
60.489.
These
include
pumps
in
light
liquid
service,
compressors,
pressure
relief
devices
in
gas/
vapor
service,
sampling
connection
systems,

open­
ended
valves
or
lines,
valves
in
gas/
vapor
service
and
light
liquid
service,
pumps
and
valves
8
in
heavy
liquid
service,
pressure
relief
devices
in
light
liquid
or
heavy
liquid
service
and
flanges
and
other
connectors.
The
regulated
pollutants
are
VOC.
This
information
is
being
collected
to
assure
compliance
with
40
CFR
Part
60,
Subpart
VV.

NSPS
Subpart
DDD:
VOC
Emissions
from
the
Polymer
Manufacturing
Industry
The
New
Source
Performance
Standards
(
NSPS)
for
the
Polymer
Manufacturing
Industry
were
proposed
on
September
30,
1987
and
January
10,
1989,
and
promulgated
on
December
11,
1990.
These
standards
apply
to
the
following
affected
facilities
involved
in
the
manufacture
of
polypropylene,
polystyrene,
or
poly(
ethylene
terephthalate)
commencing
construction,
modification
or
reconstruction
after
the
date
of
proposal
or
after
January
10,
1989,

depending
on
the
process
section.
The
affected
facilities
include:
1)
For
polypropylene
and
polyethylene
manufacturing:
each
raw
material
preparation
section,
each
polymerization
reaction
section,
each
material
recovery
section,
each
product
finishing
section,
and
each
product
storage;

2)
For
polystyrene
manufacturing
processes:
each
material
recovery
section;
and
3)
For
poly(
ethylene
terephthalate)
manufacturing:
each
polymerization
reaction
section.
For
equipment
leaks,
the
affected
facilities
are
each
group
of
fugitive
emissions
equipment
within
any
process
unit.
The
regulated
pollutants
are
VOC.
This
information
is
being
collected
to
assure
compliance
with
40
CFR
Part
60,
Subpart
DDD.

NSPS
Subpart
III:
VOC
Emissions
from
SOCMI
Air
Oxidation
Unit
Processes
The
New
Source
Performance
Standards
(
NSPS)
for
the
Synthetic
Organic
Chemical
Manufacturing
Industry
(
SOCMI)
Air
Oxidation
Unit
Processes
were
proposed
on
October
21,
1983,
and
promulgated
on
June
29,
1990.
These
standards
apply
to
the
following
facilities
for
which
construction,
modification
or
reconstruction
is
commenced
after
the
date
of
proposal:
1)
Each
air
oxidation
reactor
not
discharging
its
vent
stream
into
a
recovery
device;

2)
Each
combination
of
an
air
oxidation
reactor
and
the
recovery
system
into
which
its
vent
stream
is
discharged;
3)
Each
combination
of
two
or
more
air
oxidation
reactors
and
the
common
recovery
system
into
which
their
vent
streams
are
discharged.
The
standard
applies
to
the
affected
facility
which
produces
one
or
more
of
the
chemicals
listed
in
Section
60.617
as
a
product,
co­
product,
byproduct
or
intermediate.
The
regulated
pollutant
is
VOC.
This
information
is
being
collected
to
assure
compliance
with
40
CFR
Part
60,
Subpart
III.
9
NSPS
Subpart
NNN:
VOC
Emissions
from
SOCMI
Distillation
Operations
The
New
Source
Performance
Standards
(
NSPS)
for
the
Synthetic
Organic
Chemical
Manufacturing
Industry
(
SOCMI)
Distillation
Operations
were
proposed
on
December
30,
1983,

and
promulgated
on
June
29,
1990.
These
standards
apply
to
the
following
facilities
for
which
construction,
modification
or
reconstruction
is
commenced
after
the
date
of
proposal:
1)
Each
distillation
unit
not
discharging
its
vent
stream
into
a
recovery
device;
2)
Each
combination
of
a
distillation
unit
and
the
recovery
system
into
which
its
vent
stream
is
discharged;
3)
Each
combination
of
two
or
more
distillation
units
and
the
common
recovery
system
into
which
their
vent
streams
are
discharged.
The
standard
applies
to
affected
facilities
producing
one
or
more
of
the
chemicals
listed
in
Section
60.667
as
a
product,
co­
product,
by­
product,
or
intermediate.
The
regulated
pollutant
is
VOC.
This
information
is
being
collected
to
assure
compliance
with
40
CFR
Part
60,
Subpart
NNN.

NSPS
Subpart
RRR:
VOC
Emissions
from
SOCMI
Reactor
Processes
The
New
Source
Performance
Standards
(
NSPS)
for
the
Synthetic
Organic
Chemical
Manufacturing
Industry
(
SOCMI)
Reactor
Processes
were
proposed
on
June
29,
1990,
and
promulgated
on
August
31,
1993.
These
standards
apply
to
affected
facilities
commencing
construction,
modification
or
reconstruction
after
the
date
of
proposal:
1)
Each
reactor
process
not
discharging
its
vent
stream
into
a
recovery
system;
2)
Each
combination
of
a
reactor
processes
and
the
recovery
system
into
which
its
vent
stream
is
discharged;
3)
Each
combination
of
two
or
more
reactor
processes
and
the
common
recovery
system
into
which
their
vent
streams
are
discharged.
The
standard
applies
to
affected
facilities
producing
one
or
more
of
the
chemicals
listed
in
Section
60.707
as
a
product,
co­
product,
by­
product,
or
intermediate.
The
regulated
pollutants
are
VOC.
This
information
is
being
collected
to
assure
compliance
with
40
CFR,
Part
60,
Subpart
RRR.

NESHAP
Subpart
BB:
Benzene
Emissions
from
Benzene
Transfer
Operations
The
National
Emission
Standards
for
Benzene
Emissions
from
Benzene
Transfer
Operations
were
proposed
on
September
14,
1989,
and
promulgated
on
March
7,
1990.
The
affected
facility
to
which
this
subpart
applies
is
the
total
of
all
loading
racks
handling
a
liquid
10
containing
70
weight­
percent
or
more
benzene,
at
which
benzene
is
loaded
into
tank
trucks,

railcars,
or
marine
vessels
at
each
benzene
production
facility
and
each
bulk
terminal.
However,

specifically
exempted
from
this
regulation
are
loading
racks
at
which
only
the
following
are
loaded:
Benzene­
laden
waste
(
covered
under
Subpart
FF
of
Part
61),
gasoline,
crude
oil,
natural
gas
liquids,
petroleum
distillates
(
i.
e.,
fuel
oil,
diesel,
or
kerosene),
or
benzene­
laden
liquid
from
coke
by­
product
recovery
plants.
In
addition,
any
affected
facility
which
loads
only
liquid
containing
less
than
70
weight­
percent
benzene
or
whose
annual
benzene
loading
is
less
than
1.3
million
liters
of
70
weight­
percent
or
more
benzene
is
exempt
from
the
control
requirements
except
for
the
recordkeeping
and
reporting
requirements
in
Section
61.305(
i).
Marine
vessels
were
given
a
one
year
industry
wide
waiver
of
compliance,
which
was
later
extended
to
July
23,
1991,
in
order
to
allow
for
concurrent
compliance
with
United
States
Coast
Guard
regulations.
The
regulated
pollutant
is
benzene.
This
information
is
being
collected
to
assure
compliance
with
40
CFR
Part
61,
Subpart
BB.

NESHAP
Subpart
Y:
Benzene
Emissions
from
Benzene
Storage
Vessels
The
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
for
Benzene
Emissions
from
Storage
Vessels
were
proposed
in
1980,
and
re­
promulgated
in
1989
(
54
FR
38077)
as
40
CFR
Part
61,
Subpart
Y.
Entities
affected
by
this
action
are
those
owners
and
operators
of
benzene
storage
vessels
that
store
benzene
having
a
specific
gravity
within
the
range
of
specific
gravities
as
specified
in
the
American
Society
of
Testing
Materials
(
ASTM)

D
4734­
98
for
Refined
Benzene­
545.
Storage
vessels
with
a
design
storage
capacity
less
than
38
cubic
meters
(
10,000
gallons)
are
exempt
from
the
provisions
of
the
subpart.
Similarly,

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.
There
are
also
provisions
for
sources
subject
to
both
40
CFR
Part
61,
Subpart
Y
and
either
40
CFR
Part
60,
Subpart
K,
Ka,
or
Kb.
The
regulated
pollutant
is
benzene.
This
information
is
being
collected
to
assure
compliance
with
40
CFR
Part
61,
Subpart
Y.

NESHAP
Subpart
V:
National
Emission
Standard
for
Equipment
Leaks
(
Fugitive
Emission
Sources)
11
Affected
facilities
include
the
following
sources
that
are
intended
to
operate
in
volatile
hazardous
air
pollutant
service:
pumps,
compressors,
pressure
relief
devices,
sampling
connection
systems,
open­
ended
valves
or
lines,
valves,
flanges
and
other
connectors,
product
accumulator
vessels,
and
control
devices
or
systems.
The
standards
for
this
subpart
are
leak
detection
and
repair
(
LDAR).
The
regulated
pollutants
are
volatile
hazardous
air
pollutants.
This
information
is
being
collected
to
assure
compliance
with
40
CFR
Part
61,
Subpart
V.

NESHAP
Subparts
F,
G,
H
and
I:
The
HON
The
Maximum
Achievable
Control
Technology
(
MACT)
for
the
Hazardous
Organic
NESHAP
(
HON)
standards
were
proposed
on
December
31,
1992,
and
promulgated
on
April
22,
1994.
These
standards
apply
to
chemical
manufacturing
process
units
(
CMPU's)
in
the
SOCMI
industries
which
manufacture
as
a
primary
product
one
or
more
of
the
chemicals
listed
in
Table
1
of
40
CFR
Part
63,
Subpart
F;
use
as
a
reactant
or
manufacture
as
a
product,

by­
product,
or
co­
product,
one
or
more
of
the
organic
hazardous
air
pollutants
listed
in
Table
2
of
Subpart
F;
and
are
located
at
a
plant
site
that
is
a
major
source
as
defined
in
Section
112(
a)
of
the
Act.
Additionally,
styrene­
butadiene
rubber
production,
pesticide
production,
polybutadiene
production,
chlorinated
hydrocarbon
use
in
the
production
of
chemicals,
pharmaceutical
production,
and
miscellaneous
butadiene
use
are
subject
to
the
negotiated
regulations
affecting
equipment
leaks
promulgated
under
Subpart
I.
The
emission
points
include
transfer
racks,

storage
tanks,
wastewater
systems,
process
vents
and
equipment
leaks.
The
regulations
apply
to
existing
sources
as
well
as
new
sources
commencing
construction
or
reconstruction
after
the
date
of
proposal.
Hazardous
air
pollutants
(
HAPs)
are
the
pollutants
regulated
under
these
subparts.

This
information
is
being
collected
to
assure
compliance
with
40
CFR
Part
63,
Subparts
F,
G,
H
and
I.

2.
Need
for
and
Use
of
the
Collection
(
a)
Need/
Authority
for
the
Collection
The
CAR
is
a
pilot
project
for
an
initiative
issued
by
President
Clinton
aimed
at
reinventing
environmental
regulation.
In
the
initiative,
issued
on
March
16,
1995,

President
Clinton
called
on
EPA
to
consolidate
all
federal
air
rules
for
an
industry
sector
into
a
12
single
rule,
thereby
enhancing
understanding
and
eliminating
duplicative
or
unnecessary
compliance
activities.

The
EPA
is
charged
under
Section
111(
a)(
l)
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.

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
eight
years.

The
EPA
is
further
charged
under
Section
112
of
the
Clean
Air
Act,
as
amended,
to
establish
standards
of
performance
for
each
category
or
subcategory
of
major
sources
and
area
sources
of
hazardous
air
pollutants.
These
standards
are
applicable
to
new
or
existing
sources
of
hazardous
air
pollutants
and
shall
require
the
maximum
degree
of
emission
reduction.

In
addition,
Section
114(
a)
states
that
the
Administrator
may
require
any
owner
or
operator
subject
to
any
requirement
of
this
Act
to:

.
.
.
(
A)
establish
and
maintain
such
records,
(
B)
make
such
reports,

(
C)
install,
use,
and
maintain
such
monitoring
equipment,
and
use
such
audit
procedures,
or
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
13
compliance
certifications,
and
(
G)
provide
such
other
information
as
the
Administrator
may
reasonably
require.

(
b)
Practical
Utility/
Users
of
the
Data
The
information
collected
will
be
used
by
Agency
enforcement
personnel
to:
1)
identify
sources
subject
to
the
standards;
2)
identify
the
control
methodology
being
applied;
and
3)
ensure
that
the
emission
control
devices
are
being
properly
operated
and
maintained
on
a
continuous
basis.

In
addition,
records
and
reports
are
necessary
to
enable
EPA
to
identify
plants
that
may
not
be
in
compliance
with
the
standards.
Based
on
reported
information,
EPA
can
decide
which
plants
should
be
inspected
and
what
records
or
processes
should
be
inspected
at
the
plants.
The
records
that
plants
maintain
would
indicate
to
EPA
whether
plant
personnel
are
operating
and
maintaining
control
equipment
properly.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
(
a)
Nonduplication
For
sources
choosing
to
comply
with
the
CAR,
the
CAR's
recordkeeping
and
reporting
requirements
will
replace
the
existing
requirements
of
the
referencing
subparts.
Owners
or
operators
may
currently
be
subject
to
more
than
one
referencing
subpart,
and
may,
therefore,
be
subject
to
duplicative
recordkeeping
and
reporting
requirements.
The
CAR
provides
an
option
that
consolidates
numerous
reports
(
e.
g.,
periodic
reports
for
each
of
several
applicable
subparts)

into
a
single
report
for
all
sources
within
the
plant
site
for
which
the
owner
or
operator
has
chosen
to
comply
with
the
CAR.

Certain
reports
required
by
State
or
local
agencies
may
duplicate
information
required
by
the
CAR.
In
such
cases,
a
copy
of
the
State
or
local
agency
report
may
be
submitted
in
lieu
of
the
report
specified
in
the
Federal
regulations.

(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
Office
of
Management
and
Budget
(
OMB)
14
An
announcement
of
a
public
comment
period
for
the
renewal
of
this
ICR
was
published
in
the
Federal
Register
on
February
1,
2001,
at
66
FR
8588.
No
comments
were
received.

(
c)
Consultations
Consultations
with
numerous
representatives
of
the
SOCMI,
State
and
local
air
pollution
control
agencies,
and
other
stakeholders
were
conducted
throughout
the
development
of
the
CAR.
Table
1
provides
a
list
of
the
persons
consulted
during
the
rulemaking
effort.

(
d)
Effects
of
Less
Frequent
Collection
This
information
collection
request
includes
one­
time
initial
reports,
periodic
reports,
and
additional
reports
triggered
by
particular
activities
or
occurrences.
The
initial
reports
notify
EPA
of
applicability
and
of
initial
compliance
status.
The
CAR
does
not,
however,
require
any
initial
reports
if
the
equivalent
initial
reports
have
been
previously
submitted
under
a
referencing
subpart.
Periodic
reports
are
required
semiannually,
which
is
the
least
frequent
interval
that
would
allow
EPA
to
ensure
continuous
compliance.
Additional
reports
are
required
only
if
certain
activities
are
undertaken
(
e.
g.,
notification
of
performance
testing).
In
many
cases
these
additional
reporting
requirements
can
be
combined
with
the
periodic
report
for
the
reporting
period
immediately
following
the
activity.
The
recordkeeping
and
reporting
have
been
consolidated
to
reduce
industry
burden.
The
recordkeeping
and
reporting
frequency
cannot
be
further
reduced
without
compromising
the
Agency's
ability
to
determine
compliance
and
assure
that
the
standards
are
being
met.

(
e)
General
Guidelines
With
some
exceptions,
the
CAR
and
the
Part
63
standards
require
that
source
owners
or
operators
retain
records
for
a
period
of
5
years,
which
exceeds
the
3­
year
retention
period
contained
in
the
guidelines
in
5
CFR
1320.6.
(
This
section
pertains
to
OMB's
guidance
on
controlling
paperwork
burdens.)
The
5­
year
retention
period
is
consistent
with
the
General
Provisions
of
40
CFR
Part
63,
and
with
the
5­
year
records
retention
requirement
in
the
operating
permit
program
under
Title
V
of
the
Clean
Air
Act.
The
Part
60
and
Part
61
referencing
subparts
require
2­
year
record
retention.

(
f)
Confidentiality
The
required
information
consists
of
emissions
data
and
other
information
that
have
been
15
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
Part
2;
41
FR
36902,
September
1,
1976;
amended
by
43
FR
3999,
September
8,
1978;

43
FR
42251,
September
28,
1978;
44
FR
17674,
March
23,
1979.
Even
where
the
Agency
has
determined
that
information
received
from
a
"
person"
in
response
to
an
ICR
is
eligible
for
confidential
treatment
under
40
CFR
Part
2,
Subpart
B,
the
Agency
may
nonetheless
disclose
the
information
if
it
is
"
relevant
in
any
proceeding"
under
the
statute
[
42
U.
S.
C.
Section
7414(
c);

40
CFR,
Section
2.301(
g)].
The
information
collection
complies
with
the
Privacy
Act
of
1974
and
OMB
Circular
108.

(
g)
Sensitive
Questions
Information
to
be
reported
consists
of
emission
data
and
other
information
that
are
not
of
a
sensitive
nature.
No
sensitive
personal
or
proprietary
data
is
being
collected.

4.
The
Respondents
and
the
Information
Requested
(
a)
Respondents/
SIC
Codes
Respondents
are
owners
or
operators
of
plant
sites
subject
to
an
identified
referencing
subpart.
Referencing
subparts
include:


Standards
of
Performance
for
Storage
Vessels
for
Petroleum
Liquids
for
Which
Construction,
Reconstruction,
or
Modification
Commenced
After
May
18,
1978,
and
Prior
to
July
23,
1984
(
NSPS
Subpart
Ka)


Standards
of
Performance
for
Volatile
Organic
Liquid
Storage
Vessels
(
Including
Petroleum
Liquid
Storage
Vessels)
for
Which
Construction,
Reconstruction,
or
Modification
Commenced
After
July
23,
1984
(
NSPS
Subpart
Kb)


Standards
of
Performance
for
Equipment
Leaks
of
VOC
in
the
Synthetic
Organic
Chemicals
Manufacturing
Industry
(
NSPS
Subpart
VV)

$
Standards
of
Performance
for
Volatile
Organic
Compound
Emissions
from
the
Polymer
Manufacturing
Industry
(
NSPS
Subpart
DDD)

$
Standards
of
Performance
for
Volatile
Organic
Compound
(
VOC)
Emissions
From
the
Synthetic
Organic
Chemical
Manufacturing
Industry
(
SOCMI)
Air
Oxidation
Unit
Processes
(
NSPS
Subpart
III)
16
$
Standards
of
Performance
for
Volatile
Organic
Compound
(
VOC)
Emissions
from
Synthetic
Organic
Chemical
Manufacturing
Industry
Distillation
Operations
(
NSPS
Subpart
NNN)


Standards
of
Performance
for
Volatile
Organic
Compound
(
VOC)
Emissions
from
Synthetic
Organic
Chemical
Manufacturing
Industry
(
SOCMI)
Reactor
Processes
(
NSPS
Subpart
RRR)


National
Emission
Standards
for
Benzene
Emissions
from
Benzene
Transfer
Operations
(
NESHAP
Subpart
BB)


National
Emission
Standards
for
Benzene
Emissions
from
Benzene
Storage
Vessels
(
NESHAP
Subpart
Y)


National
Emission
Standards
for
Equipment
Leaks
(
Fugitive
Emission
Sources)
(
NESHAP
Subpart
V)


National
Emission
Standards
for
Organic
Hazardous
Air
Pollutants
from
Synthetic
Organic
Chemical
Manufacturing
Industry
for
Process
Vents,
Storage
Vessels,
Transfer
Operations,
and
Wastewater
[
NESHAP/
MACT
Subpart
G
(
the
HON)]


National
Emission
Standards
for
Organic
Hazardous
Air
Pollutants
from
Synthetic
Organic
Chemical
Manufacturing
Industry
for
Process
Vents,
Storage
Vessels,
Transfer
Operations,
and
Wastewater
[
NESHAP/
MACT
Subpart
F
(
the
HON)]


National
Emission
Standards
for
Organic
Hazardous
Air
Pollutants
for
Equipment
Leaks
[
NESHAP/
MACT
Subparts
Hand
I
(
the
HON)]

Most
of
the
sources
are
classified
in
the
four­
digit
Standard
Industrial
Classification
(
SIC)

codes
2869
for
Industrial
Organic
Chemicals
and
2865
for
Cyclic
Organic
Crudes
and
Intermediates.
Sources
classified
in
the
2911
SIC
code
(
petroleum
refining)
also
include
sources
subject
to
the
referencing
subparts.
However,
not
all
sources
classified
in
these
three
SIC
codes
would
be
regulated
by
the
referencing
subparts.
Conversely,
some
sources
in
SIC
codes
not
explicitly
listed
may
be
subject
to
a
referencing
subpart.
The
corresponding
NAICS
codes
are
primarily
32511,
325188,
32512,
and
325199.

The
SIC
codes
for
Subpart
Ka
include,
but
are
not
limited
to,
2911­
2999,
the
Petroleum
Refining
and
Related
Industries.
The
North
American
Industrial
Classification
System
(
NAICS)

code
is
predominately
32411,
petroleum
refineries.
The
NSPS
Subpart
Kb
applies
broadly
to
all
sectors
which
store
VOL,
which
include,
but
are
not
limited
to,
SIC
code
groupings
include
2811­
17
2899;
the
Chemical
and
Allied
Industries,
especially
the
Synthetic
Organic
Chemical
Manufacturing
Industry
and
2911­
2999;
the
Petroleum
Refining
and
Related
Industries,
especially
refineries
with
storage
vessels
for
the
refined
petroleum
products.

The
NSPS
Subpart
Kb
SIC
codes
and
their
corresponding
North
American
Industrial
Classification
System
(
NAICS)
codes
include,
but
are
not
limited
to:

SIC
code
2821
corresponds
to
NAICS
code
325211
SIC
code
2851
corresponds
to
NAICS
code
32551
SIC
code
2865
corresponds
to
NAICS
codes
32511,
325132
and
235192
SIC
code
2869
corresponds
to
NAICS
codes
32511,
325193
and
325199
SIC
code
2899
corresponds
to
NAICS
codes
32551
and
325199
SIC
code
2911
corresponds
to
NAICS
code
32411
SIC
code
2951
corresponds
to
NAICS
code
324121
SIC
code
2952
corresponds
to
NAICS
code
3241122
SIC
code
2992
corresponds
to
NAICS
code
324191
SIC
code
2999
corresponds
to
NAICS
code
324199
The
Subpart
DDD
SIC
codes
include,
but
are
not
limited
to,
2821
and
2824.
The
SIC
codes
for
the
SOCMI
regulations
including
NSPS
Subparts
VV,
III,
NNN,
RRR,
and
the
HON
Subparts;
MACT
Subparts
F,
G,
H,
and
I
are
primarily
2869,
although
other
source
categories
may
also
meet
the
applicability
requirements.
The
corresponding
NAICS
codes
are
32511,

325188,
32512,
and
325199.
The
SIC
code
for
NESHAP
Subpart
V
is
primarily
2865,
although
other
source
categories
may
also
meet
the
applicability
requirements;
the
corresponding
NAICS
codes
are
32511,
325132,
and
325192.
The
SIC
codes
for
NESHAP
Subpart
Y
include,
but
are
not
limited
to,
SIC
codes:
282,
286,
and
2911.
SIC
code
282
corresponds
to
NAICS
codes
325211,
325212,
325221,
and
325222.
SIC
code
286
corresponds
to
NAICS
codes
325191,

32511,
325132,
325192,
32511,
325188,
325193,
32512,
and
325199.
SIC
code
2911
corresponds
to
NAICS
code
32411.

Sources
subject
to
NESHAP
Subpart
BB
include,
but
are
not
limited
to,
the
Major
Groups
of
the
SIC
codes:
42,
44,
and
47.
Specifically:

SIC
code
4212
corresponds
to
NAICS
codes
562111,
562112,
562119,
48411,
48421
and
48422;
18
SIC
code
4213
corresponds
to
NAICS
codes
484121,
484122,
48421
and
48423;

SIC
code
4214
corresponds
to
NAICS
codes
48411,
48421
and
48422;

SIC
code
4215
corresponds
to
NAICS
codes
49211
and
49221;

SIC
code
4221
corresponds
to
NAICS
code
49313;

SIC
code
4222
corresponds
to
NAICS
code
49312;

SIC
code
4225
corresponds
to
NAICS
codes
49311
and
53113;

SIC
code
4226
corresponds
to
NAICS
codes
49312,
49311
and
49319;

SIC
code
4231
corresponds
to
NAICS
code
48849;

SIC
code
4412
corresponds
to
NAICS
code
483111;

SIC
code
4424
corresponds
to
NAICS
code
483113;

SIC
code
4432
corresponds
to
NAICS
code
483113;

SIC
code
4449
corresponds
to
NAICS
code
483211;

SIC
code
4481
corresponds
to
NAICS
codes
483112
and
483114;

SIC
code
4482
corresponds
to
NAICS
codes
483114
and
483212;

SIC
code
4489
corresponds
to
NAICS
codes
483212
and
48721;

SIC
code
4491
corresponds
to
NAICS
codes
48831
and
48832;

SIC
code
4492
corresponds
to
NAICS
code
48833;

SIC
code
4493
corresponds
to
NAICS
code
71393;

SIC
code
4499
corresponds
to
NAICS
codes
532411,
48831,
48833
and
48839;

SIC
code
4724
corresponds
to
NAICS
code
56151;

SIC
code
4725
corresponds
to
NAICS
code
56152;

SIC
code
4729
corresponds
to
NAICS
codes
488999
and
561599;

SIC
code
4731
corresponds
to
NAICS
codes
541614
and
48851;

SIC
code
4741
corresponds
to
NAICS
codes
532411
and
48821;

SIC
code
4783
corresponds
to
NAICS
codes
488991;

SIC
code
4785
corresponds
to
NAICS
codes
48839
and
48849;

SIC
code
4789
corresponds
to
NAICS
codes
488999,
48711,
72231
and
48821.

(
b)
Information
Requested
Attachment
A
lists
the
recordkeeping
and
reporting
requirements
for
the
CAR
and
the
referencing
subparts.
19
5.
The
Information
Collected:
Agency
Activities,
Collection
Methodology,
and
Information
Management
(
a)
Agency
Activities
Agency
activities
associated
with
the
CAR
and
the
referencing
subparts
include
attending
performance
tests
as
well
as
receiving
and
reviewing
notifications
and
reports.
Initial
performance
testing
and
other
initial
activities
performed
under
the
referencing
subparts
will
not
be
required
to
be
performed
again
under
the
CAR.
Implementing
agencies
will
perform
the
same
implementation
and
enforcement
activities
that
they
have
performed
pursuant
to
the
referencing
subparts.
For
sources
choosing
to
comply
with
the
CAR,
however,
there
will
be
fewer
notifications
and
reports
since
these
sources
will
be
performing
monitoring,
recordkeeping,
and
reporting
activities
to
comply
with
a
single
rule
(
the
CAR)
rather
than
to
comply
with
a
series
of
rules
(
the
applicable
referencing
subparts).
The
Agency
activities
associated
with
the
CAR
are
presented
in
Table
2,

and
the
Agency
activities
associated
with
the
referencing
subparts
are
shown
in
Tables
F1
through
F11.

(
b)
Collection
Methodology
and
Management
Information
contained
in
the
one­
time­
only
reports
will
be
entered
into
the
Aerometric
Information
Retrieval
System
(
AIRS)
Facility
Subsystem
(
AFS)
maintained
and
operated
by
EPA's
Office
of
Air
Quality
Planning
and
Standards
(
OAQPS).
Data
obtained
during
periodic
visits
by
Agency
personnel
from
records
maintained
by
the
respondents
will
be
tabulated
and
published
for
internal
EPA
use
in
compliance
and
enforcement
programs.

(
c)
Small
Entity
Flexibility
Minimizing
the
information
collection
burden
for
all
sizes
of
organizations
is
a
continuing
effort
on
EPA's
part.
The
EPA
has
reduced
the
recordkeeping
and
reporting
requirements
in
the
CAR
to
include
only
the
information
needed
by
EPA
to
determine
compliance
with
the
standards.

The
burden
to
respondents
has
been
minimized
by
requiring
the
collection
and
reporting
of
information
which
is
clearly
essential
to
ensure
that
sources
comply
with
the
standards.
The
CAR
imposes
no
net
increase
in
recordkeeping
and
reporting,
so
small
businesses
will
have
no
increased
burden.
Furthermore,
compliance
with
the
CAR
is
optional,
so
that
small
businesses
may
choose
whether
or
not
to
comply
with
the
CAR.

(
d)
Collection
Schedule
20
For
sources
that
choose
the
CAR
as
a
compliance
option,
collection
of
information
will
begin
after
a
source
implements
the
CAR.
The
CAR
allows
owners
or
operators
to
establish
their
own
compliance
schedule
provided
that
there
are
no
gaps
in
compliance
and
it
is
established
by
mutual
agreement
with
the
Administrator
or
Delegated
Authority.
Owners
and
operators
who
have
already
submitted
initial
reports
or
performance
test
results
under
the
referencing
subparts
will
not
be
required
to
resubmit
initial
reports
or
perform
another
initial
test.

Initial
notification
of
40
CFR
Part
65
applicability
is
given
in
a
Title
V
permit
application
or
modification,
or
in
a
separate
notice
for
non­
Title
V
sources,
when
the
source
owner
or
operator
makes
the
decision
to
comply
with
Part
65.
The
Initial
Notification
of
Part
65
Applicability
would
include
a
proposed
implementation
schedule.
The
compliance
schedule
along
with
the
emission
reduction
measures
that
will
be
used
to
comply
with
the
CAR
is
decided
by
mutual
agreement
with
the
Administrator
or
Delegated
Authority.

For
new
sources,
the
Notification
of
Initial
Startup
is
due
within
15
days
after
startup.
The
Initial
Compliance
Status
Report
is
due
240
days
after
the
applicable
compliance
date,
or
60
days
after
completion
of
the
initial
performance
test
or
compliance
test,
whichever
is
earlier.
However,

to
simplify
the
estimates,
EPA
has
assumed
no
new
sources
will
use
the
CAR
at
startup
during
the
three­
year
period
following
promulgation,
but
will
switch
to
the
CAR
after
startup.

Generally,
periodic
reports
would
be
submitted
semiannually.
Other
reports
would
be
submitted
as
required
by
the
provisions
for
each
kind
of
emission
point.
The
due
date
for
these
kinds
of
reports
depends
upon
the
event
that
precipitated
the
report
itself.
Examples
of
these
special
reports
include
requests
for
extensions
of
repair,
notification
of
scheduled
inspections
for
storage
vessel,
and
process
changes.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
(
a)
Estimating
Respondent
Burden
The
most
recently
approved
ICR
existing
source
annual
burden
estimates
for
reporting
and
recordkeeping
for
the
CAR
are
presented
in
Table
5.
The
most
recently
approved
existing
and
new
source
burdens
are
shown
in
Attachment
G
for
the
referencing
subparts.

(
b)
Estimating
Respondent
Cost
(
i)
Estimating
Labor
Costs
21
Table
3
also
shows
the
most
recently
approved
estimated
cost
per
source
to
respondents
for
the
CAR's
recordkeeping
and
reporting
requirements.
Attachment
G
shows
the
most
recently
approved
estimated
costs
per
source
for
the
referencing
subparts.
The
costs
incurred
consist
of
labor
costs
for
maintaining
records
and
submitting
reports.
These
cost
estimates
are
based
on
Bureau
of
Labor
Statistics
(
BLS)
rates,
and
the
specific
rates
used
for
the
CAR
and
referencing
subparts
are
listed
as
footnotes
to
the
appropriate
tables.

(
ii)
Estimating
Capital/
Startup
Costs
and
Operation
and
Maintenance
Costs
Because
we
assume
that
no
new
sources
will
opt
to
comply
with
the
CAR
at
startup
over
the
next
3
years,
there
are
no
capital
costs
associated
with
the
CAR.
Facilities
that
comply
with
the
CAR
are
assumed
to
have
already
purchased
any
equipment
needed
to
comply
with
the
referencing
subpart.
Capital/
Startup
and
O&
M
costs
for
the
referencing
subparts
are
shown
in
Table
7.
Details
of
the
capital/
startup
and
O&
M
costs,
as
taken
from
the
most
recently
approved
ICR
for
the
CAR
and
referencing
subparts,
are
detailed
in
Appendix
J3.

(
c)
Estimating
Agency
Burden
Since
the
information
collection
requirements
were
developed
as
an
incidental
part
of
standards
development,
no
costs
can
be
attributed
to
the
development
of
the
information
collection
requirements
by
the
Federal
Government.

Since
reporting
and
recordkeeping
requirements
on
the
part
of
the
respondents
are
required
under
Sections
111
and
112
of
the
Clean
Air
Act,
no
operational
costs
will
be
incurred
by
the
Federal
Government.
(
Publication
and
distribution
of
the
information
are
part
of
the
AFS
operated
and
maintained
by
OAQPS,
with
the
result
that
no
Federal
costs
can
be
directly
attributed
to
this
ICR.)

Examination
of
records
to
be
maintained
by
the
respondents
will
occur
incidentally
as
part
of
the
periodic
inspection
of
sources
that
is
part
of
EPA's
overall
compliance
and
enforcement
program
and,
therefore,
is
not
attributable
to
this
ICR.
The
only
costs
that
the
Federal
Government
will
incur
are
those
associated
with
analysis
of
reported
information.
Table
3
summarizes
the
Agency
burden
estimate
and
Attachment
F
shows
the
Agency
burden
per
referencing
subpart.

Table
7
provides
a
summary
of
the
burden
and
cost
for
the
referencing
subparts.
Detailed
burden
tables
from
the
most
recent
ICR
for
each
referencing
subpart
are
provided
in
Attachments
22
F
and
G
for
EPA
and
respondent
burden,
respectively.

Capital/
startup
and
operation
and
maintenance
costs
are
also
associated
with
several
of
the
referencing
subparts
and
are
shown
in
Table
7.
Details
of
the
capital/
startup
and
O&
M
costs,
as
taken
from
the
most
recently
approved
ICR
for
the
CAR
and
referencing
subparts,
are
detailed
in
Appendix
J3.
Capital/
startup
costs
are
one­
time
costs
associated
with
labor
and
monitoring
systems
involved
with
the
information
collection
activities
when
a
facility
becomes
subject
to
the
standard,
primarily
instrumentation
and
systems,
including
computers
and
software.
The
annual
operation
and
maintenance
costs
are
ongoing
costs
generally
associated
with
upkeep
of
monitoring
devices
and
computers.

In
addition
to
the
annual
labor
costs
associated
with
recordkeeping
and
reporting,
a
few
of
the
referencing
subparts
require
annual
expenditures
for
activities
performed
by
a
third
party.
For
Subpart
VV,
the
CAR
and
the
HON,
it
is
estimated
that
80
percent
of
facilities
will
contract
out
leak
detection
and
repair
(
LDAR)
programs.
These
costs
are
described
in
Appendix
J.

The
HON
were
used
as
a
basis
for
estimating
the
CAR
burden
because
it
is
believed
that
the
majority
of
facilities
that
opt
to
comply
with
the
CAR
will
be
HON
facilities.
Therefore,
it
is
appropriate
to
estimate
costs
for
contracting
out
LDAR
for
the
CAR
based
on
the
estimate
for
the
HON.
This
estimate
is
also
shown
in
Appendix
J.

(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
The
total
burden
for
respondents
is
the
sum
of
costs
for
technical,
managerial
and
clerical
hours
for
the
CAR
and
the
referencing
subparts.
This
is
summarized
in
Table
7.
Detailed
burden
tables
from
the
most
recently
approved
ICR
for
each
referencing
subpart
are
shown
in
Attachments
F
and
G
for
EPA
and
respondent
burden,
respectively.

(
e)
Bottom
Line
Burden
Hours
and
Cost
Tables
See
Table
7.
Detailed
burden
tables
from
the
most
recent
ICR
for
each
referencing
subpart,
with
changes
noted
in
Section
6(
f),
are
provided
in
Attachments
F
and
G
for
EPA
and
respondent
burden,
respectively
and
Attachment
J
for
Capital
Cost
and
Operation
and
Maintenance
Burden.

(
f)
Reasons
for
Change
in
Burden
The
burden
estimate
is
for
a
revision
to
the
previously
approved
ICR
for
the
CAR.
The
change
in
burden
is
attributed
to
the
consolidation
of
the
CAR
hours
with
its
referencing
subparts
23
hours.
Additionally,
a
change
in
the
method
calculating
total
annual
responses
was
performed
for
all
subparts
to
standardize
the
tables.
The
total
annual
responses,
as
specified
in
the
"
ICR
Handbook,
2/
99"
is
the
sum
of
all
responses
(
i.
e.,
required
reports
and
notifications)
required
by
the
rule
plus
the
number
of
respondents
that
kept
records
but
did
not
submit
any
responses
(
i.
e.,

only
kept
records).
Details
provided
in
Appendix
G.
For
instance,
if
all
sources
must
submit
semiannual
reports,
the
number
of
responses
per
year
would
be
two
times
the
number
of
sources
plus
zero
recordkeepers.

In
addition,
certain
specific
changes
were
made
to
the
following
referencing
subparts:

Kb:
There
is
a
change
in
the
number
of
burden
hours
(
Block
13c)
from
74,606
to
74,646
due
to
a
math
error
in
the
previously
approved
ICR.
This
change
is
reflected
in
Table
G.
2,
column
E.
Table
F.
2
was
also
revised
to
remove
EPA
burden
hours
for
records
that
the
source
produces
but
which
do
not
require
EPA
review.

VV:
The
total
burden
costs
were
adjusted
to
account
for
labor
costs
which
are
the
result
of
contracting
out
leak
detection
and
repair
programs
(
LDAR).
These
LDAR
costs
are
detailed
in
Appendix
J
and
added
to
the
costs
as
determined
in
Appendix
G
for
the
subpart.

DDD:
The
number
of
respondents,
block
13a,
was
adjusted
due
to
a
math
error
in
the
previously
submitted
ICR.
This
adjustment
also
affected
the
capital/
startup
costs,
block
14a,
the
O&
M
costs,
block
14b
and
total
capital/
startup
and
O&
M
costs,
block
14c.

III/
NNN:
The
capital/
startup
costs,
block
14a,
O&
M
costs,
block
14b,
and
total
capital/
startup
and
O&
M
costs,
block
14c,
were
adjusted
due
to
a
math
error
in
the
number
of
sources
purchasing
equipment
and
assuming
O&
M
costs.

Y:
The
previously
approved
ICR
for
40
CFR
Part
61,
Subpart
Y
covered
both
Subpart
Y
and
the
NESHAP
for
coke
by­
product
recovery
plants
(
40
CFR
Part
61,
Subpart
L).
The
coke
by­
product
recovery
plants
are
not
eligible
for
compliance
with
the
CAR.
Therefore,
this
ICR
consolidation
will
only
incorporate
the
burden
associated
with
sources
subject
to
Subpart
Y.

Subpart
L
sources
will
continue
to
be
renewed
under
the
old
ICR
(
i.
e.,
1080)

designation.
A
math
error
was
also
found
in
the
previously
approved
ICR
in
24
determining
the
number
of
burden
hours
per
year
for
annual
inspection
reports.

This
also
caused
a
change
in
the
previously
approved
burden
cost
per
year.

These
changes
are
reflected
in
Table
7
and
detailed
in
Table
G.
9.

HON:
The
total
burden
costs
were
adjusted
to
account
for
labor
costs
which
are
the
result
of
contracting
out
leak
detection
and
repair
programs
(
LDAR).
These
LDAR
costs
are
detailed
in
Appendix
J
and
added
to
the
costs
as
determined
in
Appendix
G
for
the
subpart.

CAR:
The
total
capital/
startup
costs,
block
14a,
and
the
total
capital/
startup
and
O&
M
costs,
block
14c,
were
adjusted
to
account
for
a
math
error
in
the
previously
submitted
ICR.
The
O&
M
costs
have
always
been
assumed
to
be
the
same
for
the
CAR
and
the
HON.
During
the
2001
renewal
for
the
HON,
OMB
noted
that
the
recurring
annual
O&
M
costs
for
contracting
out
leak
detection
and
repair
programs
is
actually
a
labor
cost
and
should
be
reflected
in
block
13
instead
of
block
14.
This
consolidation
standardizes
the
same
concept
for
the
CAR,
by
revising
downward
the
average
annual
O&
M
costs
from
Appendix
J3
and
moving
the
labor
costs
into
Appendix
J1.

The
sum
of
all
of
these
changes
is
reflected
in
Table
7.

(
g)
Burden
Statement
The
total
annual
reporting
and
recordkeeping
burden
for
this
information
collection
over
the
next
3
years
is
estimated
to
be
2,165,600
hours
and
$
121,333,635.
The
actual
burden
for
an
individual
respondent
will
vary
depending
on
the
size
of
the
facility,
the
number
and
types
of
equipment
for
which
the
source
chooses,
and
the
particular
compliance
options
chosen.

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
25
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,
United
States
Environmental
Protection
Agency
(
2822T),
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
series
number
and
OMB
control
number
in
any
correspondence.
26
TABLE
1:
PERSONS
CONSULTED
IN
THE
CAR
RULEMAKING
EFFORT
Name
Organization
Phone
Number
Tanveer
Anjum
Texas
(
TNRCC)
(
512)
239­
1129
Rick
Atkinson*
West
Virginia
(
WVDEP)
(
304)
588­
3745
Bill
Beck
Mobil
Oil
(
703)
846­
4755
Desi
Chari
Safety­
Kleen
Corp.
(
708)
468­
2579
Nancy
Cookson
CMA
(
202)
887­
1241
Ted
Cromwell*
CMA
(
202)
887­
1383
Norbert
Dee
NPRA
(
202)
457­
0480
John
Dege*
DuPont
(
302)
773­
0900
Mary
Sullivan
Douglas
STAPPA/
ALAPCO
(
202)
624­
7864
Sherry
Edwards
SOCMA
(
202)
414­
4170
Rob
Ferry
TGB
(
919)
664­
8250
Chuck
Grigsby
BASF/
SOCMA
(
201)
426­
2645
David
Gustafson
Dow
Chemical
(
517)
636­
2953
David
Hawkins
NRDC
(
202)
289­
2400
Bliss
Higgins*
Louisiana
DEQ
(
504)
765­
0114
Joe
Hovious
Union
Carbide
(
203)
794­
5183
Chuck
Keffer*
Monsanto
(
314)
694­
4956
Donna
King
ILTA
(
202)
659­
2301
Tom
Kittleman*
DuPont
(
302)
774­
8025
Richard
LaLumondier
ILTA
(
202)
659­
2301
Chuck
Malloch*
Consultant
to
CMA
(
314)
391­
5616
Norm
Morrow*
Exxon
Chemical
(
713)
870­
6112
Hank
Naour
Illinois
EPA
(
217)
785­
1716
Brian
Neville
ILTA
(
202)
659­
2301
Linda
Nunn
CARB
(
916)
323­
1070
Karin
Ritter
API
(
202)
682­
8472
Gene
Thomas*
Hoechst
Celanese
(
908)
231­
4476
Don
Wang*
Union
Carbide
(
304)
747­
4924
Fred
Whitcraft
DuPont
(
302)
774­
8041
David
Woodring
BP
Chemicals
(
216)
586­
8670
Joe
Woolbert*
Eastman
Chemical
(
903)
237­
5475
*
Primary
stakeholders.
27
TABLE
2:
AGENCY
ACTIVITIES
Performance
Tests
­
Initial
­
Repeat
Review
Reports
­
Notification
of
Initial
Startup
­
Notification
of
Performance
Test
­
Initial
Compliance
Status
­
Startup,
Shutdown,
Malfunction
Plans
­
Periodic
Reports
28
TABLE
3:
ANNUAL
BURDEN
AND
COST
TO
THE
FEDERAL
GOVERNMENT
FOR
THE
CAR
PROVISIONS
Burden
Item
(
Reports
to
Review)
Average
Hours
per
Activity
(
a)
Number
of
Activities
per
Year
(
b)
Estimated
Technical
Hours
per
Yeara
(
c)
Estimated
Managerial
Hours
per
Yearb
(
d)
Estimated
Clerical
Hours
per
Yearc
(
e)
Annual
Cost
in
$
Thousands
per
Yeard
(
f)

1.
Initial
Notification
of
Part
65
Applicability
2
27
e
54
3
5
2
2.
Review
Equipment
Leak
Monitoring
5
636f
3180
159
318
145
3.
Review
Periodic
Reports
4
636
2544
127
254
116
TOTAL
ANNUAL
BURDEN
AND
COST
5778
289
577
263
ac
=
a
x
b
bEstimate
managerial
hours
are
5
percent
of
technical
hours.

cEstimate
clerical
hours
are
10
percent
of
technical
hours.

dAnnual
cost
is
the
sum
of
costs
for
technical,
managerial,
and
clerical
hours
based
on
fiscal
year
1999
U.
S.
EPA
hourly
labor
rates
(
Fiscal
year
1999),
plus
overhead:

Technical
(
GS­
12,
step
5)
­
$
40
Managerial
(
GS­
15,
step
5)
­
$
66
Clerical
(
GS­
7,
step
5)
­
$
23
(
f)
=
[$
40
x
(
c)
+
$
66
x
(
d)
+
$
23
x
(
e)]/
1000
eEstimate
that
25
percent
of
320
SOCMI
facilities
which
equals
80
facilities
will
opt
to
comply
with
the
CAR
over
the
next
three
years
(
80/
3
=
27).

fEstimate
that
318
equipment
leak
sources
will
comply
with
the
CAR
(
240
from
the
HON,
59
from
Subpart
VV
and
19
from
Subpart
V).
Reports
for
equipment
leaks
will
be
submitted
semiannually
(
318
x
2
=
636
per
year).
See
Attachment
C
for
assumptions
and
further
description
of
activities.
29
TABLE
4:
ESTIMATED
NUMBER
OF
SOURCES
SUBJECT
TO
REFERENCING
SUBPARTS
THAT
WILL
OPT
TO
COMPLY
WITH
THE
CAR
Referencing
Subpart
(
A)
Estimated
Number
of
Sources
Complying
with
CARa
(
B)

Storage
Vessels
Ka
458
Kb
382
Y
0
Transfer
Racks
BB
0
Equipment
Leaks
V
19
VV
59
Process
Vents
III
1
NNN
71
RRR
8
DDD
5
HON
­
Storage
Vessels
800
Hon
­
Transfer
Racks
320
HON
­
Equipment
Leaks
240
HON
­
Process
Vents
640
aThe
number
of
sources
was
determined
from
the
supporting
statement
of
the
most
recent
information
collection
request
for
the
subpart.
A
source
is
defined
for
the
referencing
subpart
categories
as
follows;
except
for
the
HON
which
is
detailed
in
Attachment
I:


storage
vessels:
1
storage
vessel,


transfer
racks:
1
transfer
rack,


equipment
leaks:
the
collection
of
subject
equipment
for
one
process
unit,
or

process
vents:
one
process
vent.
30
TABLE
5:
ANNUAL
RESPONDENT
TECHNICAL
BURDEN
HOURS
OF
REPORTING
AND
RECORDKEEPING
FOR
THE
CAR
Burden
Item
Burden
in
Technical
Hours
Process
Vents
Storage
Vessels
Transfer
Racks
Equipment
Leaks
Inventory
Totald
With
Connectors
Without
Connectorsa
per
sourceb
totalc
per
sourceb
totalc
per
sourceb
totalc
per
sourceb
totalc
per
sourceb
totalc
per
sourceb
totalc
.
Read
Rule
and
Instructions
2.9
2,103
1.1
1,804
1.1
352
2.5
600
1.0
78
1.8
144
5,081
.
Plan
Activities
2.1
1,523
1.7
2,788
0.85
272
0.57
137
0.23
18
4.5
360
5,098
.
Training
1.3
943
0.50
820
0.50
160
0
0
0
0
0
0
1,923
.
Create,
Test,

Research
and
Development
28
20,300
16
26,240
16
5,120
380
91,200
155
12,090
0
0
154,950
.
Gather
Information,

Monitor
and
Inspect
14
10,150
17
27,880
17
5,440
263
63,120
108
8,424
54
4,320
119,334
.
Compile,
Process
and
Review
Data
0
0
0
0
0
0
0
0
0
0
18
1,440
1,440
.
Complete
Forms
9.0
6,525
5.4
8,856
5.4
1,728
57
13,680
23
1,794
5.4
432
33,015
31
.
Record/
Disclose
28
20,300
2.8
4,592
2.8
896
4.7
1,128
1.9
148
9.0
720
27,784
.
File/
Store
13
9,425
5.0
8,200
5.0
1,600
11
2,640
4.5
351
6.3
504
22,720
TOTAL
98
71,269
50
81,180
49
15,568
719
172,505
294
22,903
99
7,920
371,345
aThe
HON,
the
basis
for
the
CAR
burden
estimate,
requires
connector
monitoring.
Sources
originally
complying
with
Subpart
V
or
VV
will
not
be
required
to
perform
connector
monitoring
if
they
opt
to
comply
with
the
CAR.
For
this
reason,
a
separate
burden
estimate
was
developed
for
sources
that
are
not
required
to
perform
connector
monitoring.
The
per­
source
burden
for
these
facilities
is
the
average
of
the
per­
source
burden
for
Subparts
V
and
VV.
The
average
for
Subparts
V
and
VV
is
294
hours,
40.9
percent
less
than
the
HON­
based
estimate.
Per­
source
estimates
for
each
burden
item
were
estimated
by
multiplying
the
HON­
based
estimate
by
40.9
percent.

b
From
most
recently
approved
CAR
ICR.

cTotal
burden
for
each
source
type
is
the
product
of
the
per­
source
burden
and
the
total
number
of
sources
estimated
to
opt
to
comply
with
the
CAR.
The
number
of
sources
estimated
to
comply
with
the
CAR
are
from
the
most
recently
approved
ICR
and
are
detailed
in
Table
4:


process
vents
­
725

storage
vessels
­
1,640

transfer
racks
­
320

equipment
leaks
with
connector
monitoring
­
240

equipment
leaks
without
connector
monitoring
­
78

facilities
(
used
for
inventory
estimate)
­
80
dTotal
burden
for
each
burden
item
is
the
sum
of
totals
for
each
source
type.
This
burden
represents
technical
hours
only.
32
TABLE
6:
EXISTING
SOURCE
ANNUAL
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
FOR
THE
CAR
Burden
Item
Average
Hours
per
Activity
(
a)
Number
of
Activities
per
year
per
source
(
b)
Technical
Hours
per
year
per
source
(
c)
Estimated
Technical
Hours
per
year
(
d)
Estimated
Managerial
Hours
per
year
(
e)
Estimated
Clerical
Hours
per
year
(
f)
Annual
Cost
($
1000/
yr)

(
g)

Read
Rule
and
Instructions
2.78
23
64
5,081
254
508
315
Plan
Activities
4.92
13
64
5,098
255
510
316
Training
6.00
4.0
24
1,923
96
192
119
Create,
Test,
Research
and
Development
19.57
99
1,937
154,950
7,748
15,495
9,619
Gather
Information,

Monitor
and
Inspect
2.20
677
1,492
119,334
5,967
11,933
7,408
Compile,
Process
and
Review
Data
18.00
1.0
18
1,440
72
144
89
Complete
Forms
82.60
5.0
413
33,015
1,651
3,302
2,050
Record/
Disclose
13.35
26
347
27,784
1,389
2,778
1,725
File/
Store
8.11
35
284
22,720
1,136
2,272
1,410
TOTAL
COST
371,345
18,567
37,134
23,051
TOTAL
BURDEN
HOURS
427,046
Following
is
a
brief
explanation
of
each
column.
A
more
detailed
description
is
provided
in
Attachment
E.

(
a)
Average
hours
per
activity
are
back­
calculated
by
dividing
(
c)
by
(
b)

(
b)
Number
of
activities
per
year
is
based
on
the
estimate
of
number
of
activities
per
year
for
the
HON.
The
activities
per
year
have
been
reduced
to
reflect
the
consolidation
of
activities
achieved
through
the
CAR.

(
c)
Technical
hours
per
year
per
source
are
the
total
technical
hours
for
a
burden
item
as
estimated
in
Table
7,
divided
by
80
facilities.

(
d)
Estimated
technical
hours
per
year
are
the
total
technical
hours
for
all
facilities
for
each
burden
item,
as
estimated
in
Table
5.

(
e)
Estimated
managerial
hours
per
year
are
assumed
to
be
5
percent
of
technical
hours.
(
e)
=
(
d)
x
0.05.

(
f)
Estimated
clerical
hours
per
year
are
assumed
to
be
10
percent
of
technical
hours.
(
f)
=
(
d)
x
0.10.

(
g)
Annual
cost
is
the
sum
of
costs
for
technical,
managerial,
and
clerical
hours
based
on
the
following
U.
S.
Bureau
of
Labor
Statistics
rates
(
March
1999
rates
plus
110
percent
overhead
and
profit):

Technical
­
$
54.94
Managerial
­
$
73.93
Clerical
­
$
34.42
(
g)=
[$
54.94
x
(
d)
+
$
73.93
x
(
e)
+
$
34.42
x
(
f)]/
1000
33
TABLE
7:
SUMMARY
OF
RESPONDENT
BURDEN
AND
COST
FOR
REFERENCING
SUBPARTS
AND
THE
CAR
Subpart
ICR
Number
Number
of
Respondents
(
Block
13a)
Total
Annual
Responses
(
Block
13b)
a
Burden
Hours
(
Block
13c)
Total
Burden
Costs
Total
Capital
and
O&
M
(
Block
14
c)
in
000'
sb
Capital
Costs
(
Block
14a)

in
000'
sa
NSPS
Ka
1050.07
157
225
39,139
1,942,077
0
0
NSPS
Kb
1132.06
580
1270
74,646b
3,703,934
4,715
1,011
NSPS
VV
662.06
1120
2593
104,198
9,524,638c
35b
35b
NSPS
DDD
1150.05
90
220
12,490
686,201
960b
300
NSPS
III/
NNN
998.06
1356
3423
136,312
7,488,983
4,234b
2,403b
NSPS
RRR
1178.05
155
390
15,555
854,594
578
500
NESHAP
BB
1154.06
54
216
7,889
433,421
0
0
NESHAP
Y
1080.10
4d
8
56
b
3,088b
0
0
NESHAP
V
1153.07
21
411
23,558
1,303,699
0
0
NESHAP
F,
G,
H,

and
I
1414.04
245
1445
1,324,711
71,510,000c
67,399
24
CAR
1854.02
80
160
427,046
23,883,000c
22,000b
0
TOTAL
1854.03
3862
10,361
2,165,600
$
121,333,635
$
99,921
$
4,273
a
Difference
in
number
of
responses
from
the
most
recently
approved
ICR
described
in
Section
6(
f).

b
Difference
from
the
most
recently
approved
ICR
described
in
Section
6(
f).

c
Includes
LDAR
contractor
costs
from
Attachment
J1.

d
Does
not
include
Subpart
L
sources
(
36
sources,
7083
hours).
These
will
remain
will
EPA
Series
Number
1080.
A­
1
Attachment
A
Part
1:
Recordkeeping
and
Reporting
under
the
Consolidated
Air
Rule
1.
General
Records
$
The
owner
or
operator
shall
keep
copies
of
notifications,
reports,
and
records
as
specified
in
§
65.5.

$
The
owner
or
operator
shall
maintain
a
startup,
shutdown,
and
malfunction
plan
as
specified
in
§
65.6.

2.
Storage
Vessel
Records
$
Storage
vessel
records
where
emissions
are
controlled
by
a
fixed
roof
and
internal
floating
roof
(
IFR),
external
floating
roof
(
EFR),
or
EFR
converted
into
an
IFR
as
specified
in
§
65.47.

$
Storage
vessel
records
where
emissions
are
controlled
by
a
control
device
as
specified
in
§
65.159
for
flare
compliance
determination
and
§
65.163
for
closed
vent
systems.

$
Storage
vessel
records
where
emissions
are
routed
to
a
fuel
gas
system
or
process
as
specified
in
§
65.163.

3.
Process
Vent
Records
$
General
process
vent
records
as
specified
in
§
§
65.66,
65.63,
and
65.160.

$
Process
vent
records
where
emissions
are
controlled
by
a
control
device
as
specified
in
Section
65.159
for
flare
compliance
determination
records
and
§
§
65.162
and
65.163.

$
Process
vent
records
where
recovery
devices
are
used
to
maintain
the
TRE
index
value
above
1.0
as
specified
in
§
65.160.

4.
Transfer
Rack
Records
$
General
Transfer
Rack
Records
as
specified
in
§
§
65.83,
65.87,
and
65.160.

$
Transfer
Rack
Records
where
emissions
are
controlled
by
a
control
device
(
except
for
low­
throughput
transfer
operations)
as
specified
in
§
§
65.159,
65.162,
and
65.163.

$
Low­
throughput
transfer
operation
records
where
emissions
are
controlled
by
a
control
device
as
specified
in
§
§
65.159
and
65.163.
A­
2
5.
Equipment
Leak
Records
$
General
equipment
leak
records
as
specified
in
§
§
65.103,
65.104,
and
65.105.

$
Specific
equipment
leak
records
where
equipment
leak
emissions
are
not
controlled
by
a
control
device
or
routed
to
a
process
or
fuel
gas
system
as
specified
in
§
§
65.106,
65.109,
65.111,
and
65.120.

Equipment
leak
records
where
emissions
are
controlled
by
a
control
device
as
specified
in
§
§
65.159
and
65.163.

6.
Notification
of
Initial
Startup
$
General
contents
as
specified
in
§
§
65.5
and
65.48.

$
Initial
Notification
of
Part
65
Applicability
as
specified
in
§
65.5.

7.
Initial
Compliance
Status
Report
$
General
contents
as
specified
in
§
65.5.

$
Storage
vessels
as
specified
in
§
§
65.163
and
65.164.

$
Process
vents
as
specified
in
§
§
65.63,
65.67,
65.160,
65.164,
and
65.165.

$
Low­
volume
transfer
racks
as
specified
in
§
§
65.164
and
65.165.

$
High­
volume
transfer
racks
as
specified
in
§
§
65.83,
65.164,
and
65.165.

$
Equipment
leaks
as
specified
in
§
§
65.117,
65.118,
65.119,
and
65.120.

8.
Periodic
Reports
$
General
contents
as
specified
in
§
65.6.

$
Storage
vessel
records
where
emissions
are
controlled
by
an
IFR,
EFR,
or
EFR
converted
into
an
IFR
as
specified
in
§
65.48.

$
Storage
vessels
where
emissions
are
controlled
by
a
control
device
as
specified
in
§
§
65.166.

$
Process
vents
as
specified
in
§
§
65.67
and
65.166.

$
Low­
volume
transfer
racks
as
specified
in
§
65.166.

$
High­
volume
transfer
racks
as
specified
in
§
65.166.

$
Equipment
leaks
as
specified
in
§
65.120.

$
Closed
vent
systems
as
specified
in
§
§
65.143
and
65.166.

$
Flares
as
specified
in
§
65.166.
A­
3
9.
Other
Notification
and
Reports
$
Request
for
alteration
of
time
periods
or
postmark
as
specified
in
§
65.5.

$
Startup,
shutdown,
and
malfunction
periodic
report
as
specified
in
§
65.6
(
can
be
included
with
a
periodic
report).

$
Written
application
for
waiver
of
recordkeeping
and
reporting
requirements
as
specified
in
§
65.7.

$
Written
request
for
approval
to
use
alternatives
to
the
monitoring
or
recordkeeping
provisions
as
specified
in
§
65.7.

$
Storage
vessel
refilling
notification
as
specified
in
§
65.48.

$
Storage
vessel
seal
gap
measurement
notification
as
specified
in
§
65.48.

$
Process
vent
Group
2A
without
a
recovery
device
monitoring
and
recordkeeping
and
reporting
plan
as
specified
in
§
65.63.

$
Process
vent
report
of
a
process
change
if
not
included
with
the
periodic
report
as
specified
in
§
65.67.

$
Intent
to
conduct
a
performance
test
as
specified
in
§
65.67.

$
Process
vent
report
according
to
the
plan
for
Group
2A
process
vents
without
a
recovery
device
as
specified
in
§
65.67.

$
Equipment
leaks
written
request
for
alternative
means
of
emission
limitation
as
specified
in
§
65.102.

Part
2:
Burden
for
NSPS
sources
not
electing
to
comply
with
the
CAR
$
Initial
notifications
as
specified
in
§
60.7.

$
Provide
notification
of
construction
or
reconstruction
as
specified
in
§
60.7(
a)(
1).

$
Provide
notification
of
anticipated
startup
as
specified
in
§
60.7(
a)(
2).

$
Provide
notification
of
actual
startup
as
specified
in
§
60.7(
a)(
3).

$
Provide
notification
of
physical
or
operational
change
as
specified
in
§
60.7(
a)(
4).

$
Demonstration
of
continuous
monitoring
system
§
60.7(
a)(
5).

$
Performance
test
as
specified
in
§
60.8.

$
Report
on
initial
performance
test
results
as
specified
in
§
60.8(
a).

$
Provide
notification
of
initial
performance
test
as
specified
in
§
60.8(
d).
A­
4
Requirements
specific
to
NSPS
Subpart
Ka
$
Information
prior
to
construction
on
vapor
recovery
and
return
or
disposal
system
including
emissions
data,

operations
design
specifications
and
maintenance
plan
as
specified
in
§
60.113a(
a)(
2)(
i­
iv).

$
30
days
prior
to
seal
gap
measurement
as
specified
in
§
60.113a(
a)(
1)(
iv).

$
Report
within
60
days
when
a
seal
gap
measurement
exceeds
the
limits
of
§
60.112a
as
specified
in
§
60.113a(
a)(
1)(
i)(
E).

$
Record
gap
measurements:
Secondary
seals
every
year
and
Primary
seals
every
five
years
as
specified
in
§
60.113a
(
a)(
1)(
i)(
D).

$
Record
whenever
the
liquid
is
changed,
stored,
period
of
storage
and
maximum
true
vapor
pressure
as
specified
in
§
60.115a(
a).

Requirements
specific
to
NSPS
Subpart
Kb
$
Notification
30
days
prior
to
re/
filling
vessel
for
(
a)(
1)
and
(
a)(
4)
IFR
inspections
as
specified
in
§
60.113b(
a)(
5).

$
Notice
30
days
prior
to
seal
gap
measurements
as
specified
in
§
60.113b(
b)(
5).

$
Notification
30
days
prior
to
re/
filling
vessel
for
(
b)(
6)
EFR
inspections
as
specified
in
§
60.113b(
b)(
6).

$
Submit
operating
plan
for
closed
vent
or
exempt
control
device
as
specified
in
§
60.113b(
c).

$
Report
describing
equipment
and
certifying
control
for
IFR
as
specified
in
§
60.115b(
a)(
1).

$
Record
of
each
inspection
required
at
§
60.113b(
a),
and
40
CFR
§
60.115b(
a)(
2).

$
Report
of
visual
defects
as
specified
in
40
CFR
§
60.115b(
a)(
3).

$
Report
of
seal
holes/
tears
as
specified
in
40
CFR
§
60.115b(
a)(
4).

$
Report
describing
equipment
and
certifying
control
for
EFR
as
specified
in
40
CFR
§
60.115b(
b)(
1).

$
Report
results
of
seal
gap
measurement
required
at
§
60.113b(
b)(
1)
within
60
days
40
CFR
§
60.115b(
b)(
2).

$
Record
of
each
gap
measurement
required
at
§
60.113b(
b)
40
CFR
§
60.115b(
b)(
3).

$
Report
gaps
exceeding
limits
within
30
days
of
inspection
required
by
§
60.113b(
b)(
4)
­
40
CFR
§
60.115b(
b)(
4).

$
Records
kept
on
closed­
vent
system
as
specified
in
40
CFR
§
60.115b(
c).

$
Report
of
flare
measurements
as
specified
in
40
CFR
§
60.115b(
d)(
1).

$
Records
kept
on
flare
as
specified
in
40
CFR
§
60.115b(
d)(
2).

$
Report
semiannually
periods
of
pilot
flame
absent
from
flare
as
specified
in
40
CFR
§
60.115b(
d)(
3).

$
Records
of
dimensions
and
capacity
of
vessel
as
specified
in
40
CFR
§
60.116b(
b).

$
Record
of
VOL
stored,
period
of
storage,
and
maximum
true
vapor
pressure
of
lower
kPa
vessels
as
specified
in
40
CFR
§
60.116b(
c).

$
Record
of
VOL
stored,
period
of
storage,
and
maximum
true
vapor
pressure
of
higher
kPa
vessels
as
specified
in
40
CFR
§
60.116b(
d).
A­
5
Requirements
specific
to
NSPS
Subpart
VV
$
Recordkeeping
as
specified
in
40
CFR
§
60.486.

$
Semiannual
reporting
requirements
as
specified
in
40
CFR
§
60.487(
a),
40
CFR
§
60.487(
b),
40
CFR
§
60.487(
c).

$
Notification
of
alternative
standard
selected
as
specified
in
§
60.487(
d).

$
Report
Performance
tests
as
specified
in
§
60.487(
e).

Requirements
specific
to
NSPS
Subpart
DDD
$
Initial
performance
test
results
or
specified
alternative
reports
as
specified
in
40
CFR
§
60.565.

$
Semiannual
reports
of
deviations
from
monitoring
parameters,
monitoring
exceedances,
changes
in
process
operations,
and
periods
during
which
control
device
is
inoperative
as
specified
in
40
CFR
§
60.565(
k).

$
Records
of
periods
when
flow
monitor
indicates
emission
stream
is
being
diverted
away
from
the
control
device
as
specified
in
40
CFR
§
60.565(
b).

$
Records
of
monitoring
parameters
as
specified
in
40
CFR
§
60.565(
c),
(
d),
(
e),
(
f),
(
g),
(
h).

$
Results
of
monitoring
during
performance
tests,
including
the
vent
system
used
to
vent
each
affected
stream
to
the
control
device;
evidence
of
compliance
with
incineration
requirements;
evidence
of
compliance
with
boiler
or
process
heater
operation,
and
records
from
flare
or
pilot
light
flame
heat
sensing
monitoring
and
periods
of
operation
when
the
flare
or
pilot
flame
is
absent
as
specified
in
40
CFR
§
60.565(
a),
(
b),
(
c),
(
d),
(
e),
(
f).

$
Changes
in
production
capacity,
feedstock
type,
or
catalyst
type
or
replacement,
removal
or
addition
of
product
recovery
equipment
or
an
air
oxidation
reactor
as
specified
in
40
CFR
§
60.565(
g).

$
Evidence
of
compliance
with
elected
alternative
provisions,
and
all
periods
of
operation
during
which
the
performance
boundaries
are
exceeded
as
specified
in
40
CFR
§
60.565(
h).

Requirements
specific
to
NSPS
Subpart
III
$
Notification
of
the
specific
provisions
of
the
standards
which
the
owner
has
elected
to
comply
as
specified
in
40
CFR
§
60.615(
a).

$
Record
data
measured
during
each
performance
test
as
specified
in
40
CFR
§
60.615(
b)
and
40
CFR
§
60.615(
h)(
3).

$
Continuously
record
equipment
operating
parameters
as
specified
in
40
CFR
§
60.615(
c)
and
40
CFR
§
60.615(
g).

$
Record
periods
of
operation
during
which
the
performance
boundaries
established
during
the
most
recent
performance
test
are
exceeded
as
specified
in
40
CFR
§
60.615(
c)
and
40
CFR
§
60.615(
g).

$
Continuously
record
the
indication
of
vent
stream
flow
to
the
control
device
as
specified
in
40
CFR
§
60.615(
d).

$
Record
all
periods
of
operation
of
a
boiler
or
process
heater
as
specified
in
40
CFR
§
60.615(
e).

$
Record
results
of
flare
pilot
flame
monitoring
and
all
periods
of
operations
in
which
the
pilot
flame
is
absent
as
A­
6
specified
in
40
CFR
§
60.615(
f).

$
Record
changes
in
production
capacity,
feedstock
type,
catalyst
type,
or
replacement,
removal
or
addition
of
recovery
equipment
or
an
air
oxidation
reactor
as
specified
in
40
CFR
§
60.615(
h)(
1).

$
Record
any
recalculation
of
the
TRE
index
value
as
specified
in
40
CFR
§
60.615(
h)(
2).

$
Written
report
of
initial
performance
test
results
as
specified
in
40
CFR
§
60.8
and
40
CFR
§
60.615(
b).

$
For
the
semiannual
report
exceedances
of
parameter
boundaries
established
during
the
most
recent
performance
test
as
specified
in
40
CFR
§
60.615(
j)(
1).

$
For
the
semiannual
report
all
periods
when
the
vent
stream
is
diverted
from
the
control
device
or
has
no
flowrate
as
specified
in
40
CFR
§
60.615(
j)(
2).

$
For
the
semiannual
report
all
periods
when
the
boiler
or
process
heater
was
not
operated
as
specified
in
40
CFR
§
60.615(
j)(
3).

$
For
the
semiannual
report
all
periods
in
which
the
flare
pilot
flame
was
absent
as
specified
in
40
CFR
§
60.615(
j)(
4).

$
For
the
semiannual
report
any
recalculation
of
the
TRE
index
value
as
specified
in
40
CFR
§
60.615(
j)(
5).

Requirements
specific
to
NSPS
Subpart
NNN
$
Notification
of
the
specific
provisions
of
the
standards
which
the
owner
has
elected
to
comply
as
specified
in
40
CFR
§
60.665(
a).

$
Record
data
measured
during
each
performance
test
as
specified
in
40
CFR
§
60.665(
b)
and
40
CFR
§
60.665(
h)(
3).

$
Continuously
record
equipment
operating
parameters
as
specified
in
40
CFR
§
60.665
and
40
CFR
§
60.665(
g).

$
Record
periods
of
operation
during
which
the
performance
boundaries
established
during
the
most
recent
performance
test
are
exceeded
as
specified
in
40
CFR
§
60.665
and
40
CFR
§
60.665(
g).

$
Continuously
record
the
indication
of
vent
stream
flow
to
the
control
device
as
specified
in
40
CFR
§
60.665(
d).

$
Record
all
periods
of
operation
of
a
boiler
or
process
heater
as
specified
in
40
CFR
§
60.665(
e).

$
Record
results
of
flare
pilot
flame
monitoring
and
all
periods
of
operations
in
which
the
pilot
flame
is
absent
as
specified
in
40
CFR
§
60.665(
f).

$
Record
changes
in
production
capacity,
feedstock
type,
catalyst
type,
or
replacement,
removal
or
addition
of
recovery
equipment
or
an
air
oxidation
reactor
as
specified
in
40
CFR
§
60.665(
h)(
1).

$
Record
any
recalculation
of
the
TRE
index
value
as
specified
in
40
CFR
§
60.665(
h)(
2).

$
Record
data
showing
that
the
vent
stream
flowrate
is
less
than
0.008
m3/
min
and
any
change
in
equipment
or
process
operation
that
increases
the
operating
vent
stream
flowrate
including
a
measurement
of
the
new
flowrate
as
specified
in
40
CFR
§
60.665(
i).

$
Record
any
change
in
equipment
or
process
operation
that
increases
the
design
production
capacity
of
the
A­
7
process
unit
as
specified
in
40
CFR
§
60.665(
j).

$
Written
report
of
performance
test
results
as
specified
in
40
CFR
§
60.8
and
40
CFR
§
60.665(
b).

$
For
demonstrating
compliance
with
the
low
capacity
exemption
levels,
a
report
detailing
the
design
production
capacity
of
the
process
unit
as
specified
in
40
CFR
§
60.665(
n).

$
For
demonstrating
compliance
with
the
low
flow
exemption
level,
a
report
of
the
flowrate
measurement
as
specified
in
40
CFR
§
60.665(
o).

$
For
the
semiannual
report
exceedances
of
parameter
boundaries
established
during
the
most
recent
performance
test
as
specified
in
40
CFR
§
60.665(
l)(
1).

$
For
the
semiannual
report
all
periods
when
the
vent
stream
is
diverted
from
the
control
device
or
has
no
flowrate
as
specified
in
40
CFR
§
60.665(
l)(
2).

$
For
the
semiannual
report
all
periods
when
the
boiler
or
process
heater
was
not
operated
as
specified
in
40
CFR
§
60.665(
l)(
3).

$
For
the
semiannual
report
all
periods
in
which
the
flare
pilot
flame
was
absent
as
specified
in
40
CFR
§
60.615(
j)(
4).

$
For
the
semiannual
report
any
change
in
equipment
or
process
operation
that
increases
the
operating
vent
stream
flowrate
above
the
low
flow
exemption
level
as
specified
in
40
CFR
§
60.665(
l)(
5).

$
For
the
semiannual
report
any
change
in
equipment
or
process
operation
that
increases
the
design
production
capacity
above
the
low
capacity
exemption
level
as
specified
in
40
CFR
§
60.665(
l)(
6).

$
For
the
semiannual
report
any
recalculation
of
the
TRE
index
value
as
specified
in
40
CFR
§
60.665(
l)(
7).

Requirements
specific
to
NSPS
Subpart
RRR
$
Notification
of
the
specific
provisions
of
the
standards
which
the
owner
has
elected
to
comply
as
specified
in
40
CFR
§
60.705(
a).

$
Exceedances
of
parameter
boundaries
established
during
the
most
recent
performance
test
as
specified
in
40
CFR
§
60.705(
l)(
1).

$
All
periods
when
the
vent
stream
is
diverted
from
the
control
device
or
has
no
flowrate
as
specified
in
40
CFR
§
60.705(
l)(
2).

$
All
periods
in
which
the
flare
pilot
flame
was
absent
as
specified
in
40
CFR
§
60.705(
l)(
3).

$
For
the
Semiannual
Report,
any
changes
in
equipment
or
process
operation
that
increases
the
operating
vent
stream
flowrate
above
the
low
flow
exemption
level
as
specified
in
40
CFR
§
60.705(
l)(
4).

$
For
the
Semiannual
Report,
any
change
in
equipment
or
process
operation,
that
increases
the
design
production
capacity
above
the
low
capacity
exemption
level
as
specified
in
40
CFR
§
60.705(
l)(
5).

$
For
the
Semiannual
Report,
any
recalculation
of
the
TRE
index
value
as
specified
in
40
CFR
§
60.705(
l)(
6).

$
For
the
Semiannual
Report,
all
periods
recorded
in
which
the
seal
mechanism
is
broken
or
the
bypass
line
valve
position
has
changed.
A
record
of
the
serial
number
of
the
car­
seal
or
a
record
to
show
that
the
key
to
unlock
A­
8
the
bypass
line
valve
was
checked
out
must
be
maintained
to
demonstrate
the
period,
the
duration,
and
frequency
in
which
the
bypass
line
was
operated
as
specified
in
40
CFR
§
60.705(
l)(
7).

$
For
the
Semiannual
Report,
any
change
in
equipment
or
process
operation
that
increases
the
vent
stream
concentration
above
the
low
concentration
exemption
level,
including
a
measurement
of
the
new
vent
stream
concentration
as
specified
in
40
CFR
§
60.705(
l)(
8).

$
For
the
Initial
Report,
written
report
of
performance
test
results
as
specified
in
40
CFR
§
60.8
and
40
CFR
§
60.705(
b).

$
Record
data
measured
during
each
performance
test
as
specified
in
40
CFR
§
60.705(
b)
and
40
CFR
§
60.705(
g)(
3).

$
Continuously
record
equipment
operating
parameters
as
specified
in
40
CFR
§
60.705(
c).

$
Records
of
diversion
of
vent
stream
from
the
control
device
as
specified
in
40
CFR
§
60.705(
d)(
1).

$
Record
results
of
flare
pilot
flame
monitoring
and
all
periods
of
operations
in
which
the
pilot
flame
is
absent
as
specified
in
40
CFR
§
60.705(
e).

$
Record
periods
of
operation
during
which
the
performance
boundaries
established
during
the
most
recent
performance
test
are
exceeded
as
specified
in
40
CFR
§
60.705(
f).

$
Record
changes
in
production
capacity,
feedstock
type,
catalyst
type,
or
replacement,
removal
or
addition
of
recovery
equipment
as
specified
in
40
CFR
§
60.705(
g)(
1).

$
Record
any
recalculation
of
the
TRE
index
value
as
specified
in
40
CFR
§
60.705(
g)(
2).

$
Records
to
indicate
that
the
vent
stream
flowrate
is
less
than
0.011
scm/
min
and
of
any
change
in
equipment
or
process
operation
that
increases
the
operating
vent
stream
flowrate,
including
measurement
of
the
new
vent
stream
flowrate
as
specified
in
40
CFR
§
60.705(
h).

$
Each
owner
or
operator
of
an
affected
facility
that
seeks
to
comply
with
the
requirements
of
this
subpart
by
complying
with
the
design
production
capacity
provision,
shall
keep
up­
to­
date,
readily
accessible
records
of
any
change
in
equipment
or
process
operation
that
in
creases
the
design
production
capacity
of
the
process
unit
in
which
the
affected
facility
is
located
as
specified
in
40
CFR
§
60.705(
i).

$
Each
owner
or
operator
of
an
affected
facility
that
seeks
to
complying
with
the
low
concentration
exemption,

shall
keep
up­
to­
date,
readily
accessible
records
of
any
change
in
equipment
or
process
operation
that
increases
the
concentration
of
the
vent
stream
of
the
affected
facility
as
specified
in
40
CFR
§
60.705(
j).

Part
3:
Burden
for
40
CFR
Part
61
NESHAP
sources
not
electing
to
comply
with
the
CAR
$
Construction
or
modification
application
as
specified
in
40
CFR
§
61.07.

$
Provide
notification
of
anticipated
startup
as
specified
in
40
CFR
§
61.09(
a)(
1).

$
Provide
notification
of
actual
startup
as
specified
in
40
CFR
§
61.09(
a)(
2).

$
Source
status
report
as
specified
in
40
CFR
§
61.10(
a).

$
Initial
performance
test
as
specified
in
40
CFR
§
61.13.
A­
9
$
Provide
notification
of
initial
performance
test
as
specified
in
40
CFR
§
61.13.

$
Report
on
initial
performance
test
results
as
specified
in
40
CFR
§
61.13(
f).

$
Provide
notification
of
physical
or
operational
change
as
specified
in
40
CFR
§
61.15
.

Requirements
specific
to
NESHAP
Subpart
V
$
Application
for
alternative
means
of
emissions
limitation
as
specified
in
40
CFR
§
61.244.

$
Recordkeeping
as
specified
in
40
CFR
§
61.246.

$
Reporting
as
specified
in
40
CFR
§
61.247.

Requirements
specific
to
NESHAP
Subpart
Y
$
Initial
source
report
as
specified
in
40
CFR
§
61.274.

$
Report
of
annual
and
periodic
inspections
for
IFR
as
specified
in
40
CFR
§
61.275(
a).

$
Supplemental
annual
period
k
report
for
IFR
as
specified
in
40
CFR
§
61.275(
a).

$
Report
of
5
or
10
year
internal
inspections
for
IFR
as
specified
in
40
CFR
§
61.275(
b).

$
Report
of
annual
seal
gap
measurements
for
EFR
as
specified
in
40
CFR
§
61.275(
d).

$
Report
of
5
year
seal
gap
measurements
for
EFR
as
specified
in
40
CFR
§
61.275(
d).

$
Report
of
excess
emissions
for
closed
vent
systems
with
control
devices
as
specified
in
40
CFR
§
61.275(
e).

$
Record
of
storage
vessel
design
capacity
as
specified
in
40
CFR
§
61.276(
b).

$
Record
of
information
on
closed
vent
systems
with
control
devices
as
specified
in
40
CFR
§
61.276(
c).

Requirements
specific
to
NESHAP
Subpart
BB
$
Obtain
vapor
tightness
documentation
at
40
CFR
§
61.305(
h)
every
12
months
as
specified
in
40
CFR
§
61.302(
d).

$
Maintain
vapor­
tightness
file
on
each
affected
facility
as
specified
in
40
CFR
40
CFR
§
61.302(
d)
and
(
e).

$
Record
of
measurements
during
each
performance
test
as
specified
in
40
CFR
§
61.305(
a).

$
Engineering
report
as
specified
in
40
CFR
§
61.305(
a)(
5).

$
Record
of
monitoring
equipment
parameters
and
excess
emissions
as
specified
in
40
CFR
§
61.305(
b).

$
Record
vent
valves
status
and
maintain
for
at
least
two
years
as
specified
in
40
CFR
§
61.305(
c).

$
Records
of
periods
of
operation
of
steam
generator
or
process
heater
kept
up­
to­
date
as
specified
in
40
CFR
§
61.305(
d).

$
Records
of
flare
operation
and
monitoring
kept
up­
to­
date
as
specified
in
40
CFR
§
61.305(
e).

$
Quarterly
report
by
sources
subject
to
as
specified
in
40
CFR
§
61.302,
and
controls
as
specified
in
40
CFR
§
61.305(
f).

$
Documentation
of
vapor­
tightness
required
under
40
CFR
§
61.302(
d)
and
(
e)
on
permanent
file
40
CFR
§
61.305
(
g).
A­
10
$
Documentation
of
vapor­
tightness
renewed
at
least
once
per
year
as
specified
in
40
CFR
§
61.305(
h).

$
Record
and
report
information
when
exempt
under
40
CFR
§
61.300(
b)
40
CFR
§
61.305(
i).

$
Record
of
closed­
vent
system
annual
leak
inspection
required
at
40
CFR
§
61.242­
ll(
f)(
2)
through
40
CFR
§
61.302(
k),
40
CFR
§
61.246(
d).

Part
4:
Burden
for
40
CFR
Part
63
NESHAP
sources
not
electing
to
comply
with
the
CAR
(
MACT
Subparts
F,
G,
H
and
I:
The
HON)

Notification
$
Notification
of
construction
or
reconstruction
as
specified
in
40
CFR
§
63.5,
40
CFR
§
63.9,
40
CFR
§
63.100,
40
CFR
§
63.151,
40
CFR
§
63.182,
40
CFR
§
63.192.

$
Notification
of
anticipated
date
of
initial
startup
as
specified
in
40
CFR
§
63.5,
40
CFR
§
63.9,
40
CFR
§
63.151,

40
CFR
§
63.182,
40
CFR
§
63.192.

$
Notification
of
actual
date
of
initial
startup
as
specified
in
40
CFR
§
63.9,
40
CFR
§
63.151,
§
63.182,
§
63.192.

$
Notification
of
process
changes
40
CFR
§
63.100,
40
CFR
§
63.118,
40
CFR
§
63.146,
40
CFR
§
63.151,
40
CFR
§
63.152,
40
CFR
§
63.182,
40
CFR
§
63.192.

$
Notification
of
performance
test
as
specified
in
40
CFR
§
63.103.

$
Notification
for
storage
tanks
as
specified
in
40
CFR
§
63.192.

Reporting
­
Initial
and
Notification
of
Compliance
Status
$
Initial
report
requirements
as
specified
in
40
CFR
§
63.117,
40
CFR
§
63.122,
40
CFR
§
63.129,
40
CFR
§
63.146,

40
CFR
§
63.151,
40
CFR
§
63.182,
40
CFR
§
63.192.

$
Reporting
of
operating
parameter
levels
as
specified
in
40
CFR
§
63.117,
40
CFR
§
63.120,
40
CFR
§
63.122,
40
CFR
§
63.129,
40
CFR
§
63.130,
40
CFR
§
63.146,
40
CFR
§
63.151,
40
CFR
§
63.182,
40
CFR
§
63.192.

$
Statement
of
compliance/
noncompliance
as
specified
in
40
CFR
§
63.117,
40
CFR
§
63.120,
40
CFR
§
63.122,
40
CFR
§
63.127,
40
CFR
§
63.128,
40
CFR
§
63.129,
40
CFR
§
63.151,
40
CFR
§
63.152,
40
CFR
§
63.182,
40
CFR
§
63.192.

Reporting
­
Periodic
and
Event
Triggered
$
Startup,
shutdown
and
malfunction
as
specified
in
40
CFR
§
63.6,
40
CFR
§
63.10,
40
CFR
§
63.103,
40
CFR
§
63.105.
B­
1
$
Exceedance
of
parameter
boundaries
established
during
the
most
recent
performance
test
as
specified
in
40
CFR
§
63.118,
40
CFR
§
63.122,
40
CFR
§
63.130,
40
CFR
§
63.146,
40
CFR
§
63.148,
40
CFR
§
63.151,
40
CFR
§
63.152,
40
CFR
§
63.182,
40
CFR
§
63.192.

$
Any
change
in
equipment
or
process
operation
that
increases
emission
levels
above
requirements
in
the
standard
as
specified
in
§
63.103,
§
63.104,
§
63.122,
§
63.130,
§
63.146,
§
63.148,
§
63.151,
§
63.152,
§
63.182,
§
63.192.

$
Written
report
of
performance
tests
as
specified
in
40
CFR
§
63.117,
40
CFR
§
63.120,
40
CFR
§
63.122,
40
CFR
§
63.129,
40
CFR
§
63.146,
40
CFR
§
63.151,
40
CFR
§
63.152,
40
CFR
§
63.182,
40
CFR
§
63.192.

$
Delay
of
repair
as
specified
in
40
CFR
§
63.104,
40
CFR
§
63.122,
40
CFR
§
63.182,
40
CFR
§
63.192.

Recordkeeping
$
General
Recordkeeping
as
specified
in
40
CFR
§
63.103.

$
Record
of
data
measured
during
each
performance
test
as
specified
in
40
CFR
§
63.117,
40
CFR
§
63.118,
40
CFR
§
63.123,
40
CFR
§
63.129,
40
CFR
§
63.130,
40
CFR
§
63.147,
40
CFR
§
63.148,
40
CFR
§
63.151,
40
CFR
§
63.152,
40
CFR
§
63.181,
40
CFR
§
63.192.

$
Record
of
periods
of
operation
during
which
the
performance
boundaries
established
in
the
Notification
of
Compliance
Status
are
exceeded
as
specified
in
40
CFR
§
63.118,
40
CFR
§
63.120,
40
CFR
§
63.123,
40
CFR
§
63.130,
40
CFR
§
63.147,
40
CFR
§
63.148,
40
CFR
§
63.151,
40
CFR
§
63.152.

$
Records
of
Monthly
visual
inspections
as
specified
in
40
CFR
§
63.118,
40
CFR
§
63.130,
40
CFR
§
63.147,
40
CFR
§
63.148,
40
CFR
§
63.181,
40
CFR
§
63.192.

$
Records
of
Annual
visual
inspections
as
specified
in
40
CFR
§
63.123,
40
CFR
§
63.147,
40
CFR
§
63.148,
40
CFR
§
63.181
40
CFR
§
63.192.

$
TRE
records
for
process
vents
as
specified
in
40
CFR
§
63.117.

$
Monitoring
records
as
specified
in
40
CFR
§
63.118,
40
CFR
§
63.123.

$
Records
of
process
changes
for
process
vents
as
specified
in
40
CFR
§
63.118.

$
Records
of
delay
of
repair
as
specified
in
40
CFR
§
63.120,
40
CFR
§
63.123.

$
Record
of
storage
vessel
size
as
specified
in
40
CFR
§
63.123.

$
Record
of
vent
system
configuration
for
transfer
racks
as
specified
in
40
CFR
§
63.129.

$
Record
of
design
criteria
for
equipment
leaks
as
specified
in
40
CFR
§
63.118.

$
Record
of
startup,
shutdown
and
malfunction
as
specified
in
40
CFR
§
63.6,
40
CFR
§
63.103,
40
CFR
§
63.105,

40
CFR
§
63.152.

$
Records
of
continuous
monitoring
systems
as
specified
in
40
CFR
§
63.103.

Attachment
B
B­
2
Purposefully
left
blank
C­
1
Attachment
C
Assumptions
and
Item
Descriptions
for
Table
3
Assumptions
are
the
same
as
Attachment
E,
and:

(
A)
That
there
are
318
total
sources
(
240
from
the
HON,
59
from
Subpart
VV,
and
19
from
Subpart
V)
that
must
submit
semiannual
reports
from
equipment
leak
detection
and
repair
programs
as
well
as
semiannual
periodic
reports.
This
equates
to
636
EPA
activities
(
318
*
2)
during
each
of
the
three
years
following
promulgation.

(
B)
That
all
sources
must
submit
an
Initial
Notification
of
Part
65
Applicability
or
submit
the
corresponding
information
in
a
modification
to
their
Title
V
permits.
This
equates
to
80
EPA
activities,
or
27
per
year
(
80/
3)
during
each
of
the
three
years
following
promulgation.

Item
descriptions:

(
a)
Average
Hours
per
Activity
are
estimates
of
the
specific
activities
and
are
the
basis
for
estimating
the
overall
burden.

(
b)
Number
of
Activities
per
Year
represents
the
number
of
reports
expected
to
be
reviewed
and
other
related
activities
during
the
course
of
the
year,
based
upon
assumptions
(
A)
and
(
B).

(
c)
Estimated
Technical
Hours
per
Year
is
the
product
of
(
a)
and
(
b).

(
d)
Estimated
Managerial
Hours
per
Year
is
5
percent
of
(
c).

(
e)
Estimated
Clerical
Hours
per
Year
is
10
percent
of
(
c).

(
f)
Estimated
Annual
Cost
in
$
Thousands
per
Year
is
the
total
cost
of
technical,
managerial,
and
clerical
hours
and
overhead
using
this
formula:

(
Ht
*
$
40/
hour)
+
(
Hm
*
$
66/
hour)
+
(
Hc
*
$
23/
hour)
=
(
h)

1,000
C­
2
Where:
Ht
is
(
c),
or
technical
hours,

Hm
is
(
d),
or
managerial
hours,
and
Hc
is
(
e),
or
clerical
hours.

Source:
EPA
Labor
Rates
(
Fiscal
Year
1999)

Technical:
25.21
(
GS­
12,
step
5)

Managerial:
41.66
(
GS­
15,
step
5)

Clerical:
14.21
(
GS­
7,
step
5)

plus
60
percent
for
overhead
and
benefits
1)
Initial
Notification
of
Part
65
Applicability/
Title
V
Modification
represents
the
EPA
review
of
either
the
Initial
Notification
of
Part
65
Applicability
report
or
the
source's
Title
V
modification
through
which
the
source
notifies
EPA
that
it
intends
to
comply
with
the
CAR.
As
noted
in
the
supporting
statement
text,
the
EPA
does
not
expect
any
new
sources
to
elect
to
comply
with
the
CAR
during
the
3­
year
period
following
promulgation.

2)
Review
Equipment
Leak
Monitoring
represents
the
review
and
screening
of
periodic
reports
received
as
a
result
of
the
equipment
leaks
standard.

3)
Review
Periodic
Reports
represents
the
EPA
review
of
periodic
reports
from
new
and
existing
sources.

TOTAL
BURDEN
AND
COST
is
the
total
for
each
of
the
columns
(
c),
(
d),
(
e),
and
(
f).
D­
1
Attachment
D
Purposefully
left
blank
E­
1
Attachment
E
Assumptions
and
Item
Descriptions
for
Table
6
Assumptions
are:

(
A)
That
there
are
320
existing
facilities
of
which,
25
percent
(
80)
chose
to
comply
with
the
CAR.

(
B)
That
the
average
representative
source
will
consist
of
a
variety
of
sources.
The
total
number
of
sources
expected
to
comply
with
the
CAR
includes
(
From
Table
4):


1,640
storage
vessel;


320
transfer
racks;


240
collections
of
subject
equipment,
including
connectors;


78
collections
of
subject
equipment
not
including
connectors;


80
facility
wide
inventories
of
emission
points;
and

725
process
vents.

(
C)
That
there
are
5
percent
(
0.05)
managerial
and
10
percent
(
0.10)
clerical
hours
required
for
every
technical
hour.

(
D)
That
some
activities
necessary
to
generate
reports
involve
creating
records
in
the
process,
and
that
these
activities
are
assumed
to
be
reports
activities
alone,
to
avoid
double
counting
these
as
records
activities
as
well.
Therefore,
only
items
8
and
9
are
considered
records
burdens
directly.

Item
descriptions:

(
a)
Average
Hours
per
Activity
is
back­
calculated
by
dividing
(
b)
into
(
c).
Since
the
activities
within
each
burden
category
can
vary
significantly,
it
is
too
inaccurate
to
assume
an
average
to
use
to
calculate
(
c).
Estimated
activity
technical
hours
are
summarized
to
obtain
(
c)
first,
then
back­
calculated
for
(
a)
with
an
estimated
(
b).

(
b)
Estimated
Number
of
Activities
per
Year
per
Source
represents
the
assumed
typical
number
of
separate
activities
a
source
may
encounter
during
one
year.
This
number
may
vary
from
facility
to
facility
depending
on
consolidation
of
activities,

co­
located
readings,
etc.
Since
so
much
variability
exists,
it
is
important
to
note
that
this
an
estimate.
This
number
was
only
used
to
back
calculate
(
a).
The
numbers
are
based
on
the
number
of
activities
per
year
estimated
for
complying
with
the
HON.

The
numbers
have
been
reduced
to
reflect
the
consolidation
of
activities
achieved
through
the
CAR.
E­
2
(
c)
Technical
Hours
per
Year
per
Source
is
the
total
technical
hours
for
a
burden
item,
as
estimated
in
Table
7
divided
by
80
facilities.
Because
of
the
variability
in
the
number
and
combination
of
sources
at
a
facility,
this
value
could
vary
widely.

(
d)
Estimated
Technical
Hours
per
Year
is
the
sum
of
total
technical
hours
for
all
sources
for
each
burden
item,
as
estimated
in
Table
7.

(
e)
Estimated
Managerial
Hours
per
Year
is
5
percent
of
(
d).

(
f)
Estimated
Clerical
Hours
per
Year
is
10
percent
of
(
d).

(
g)
Estimated
Annual
Cost
in
Thousands
of
Dollars
per
Year
is
the
total
cost
of
technical,
managerial,
and
clerical
hours
and
overhead
using
this
formula:

(
Ht
*
$
54.94/
hour)
+
(
Hm
*
$
73.93/
hour)
+
(
Hc
*
$
34.42/
hour)=(
g)
$
1,000
Where:

Ht
is
(
d),
or
technical
hours,

Hm
is
(
e),
or
managerial
hours,
and
Hc
is
(
f),
or
clerical
hours.

Source:
Employer
Costs
for
Employee
Compensation
­
March
1999.

U.
S.
Department
of
Labor,
Bureau
of
Labor
Statistics,
June
24,
1999.
Rates
multiplied
by
110
percent
to
account
for
overhead
and
profit.

1)
Read
Rule
and
Instructions
consists
of
the
activities,
less
training,
which
involve
comprehending
the
provisions
in
the
standard
and
understanding
how
they
apply
to
the
respective
points
at
a
facility.

2)
Plan
Activities
represents
such
burdens
as
design,
redesign,
and
scheduling
as
well
as
selecting
methods
of
compliance.

3)
Training
represents
the
portion
of
activities
from
1)
Read
Rule
and
Instructions
for
which
an
average
facility
would
elect
to
provide
class
room
instruction.
The
standard
does
not
require
specific
training
itself.
E­
3
4)
Create,
Test,
Research
and
Development
are
the
activities
involving
testing,
retesting,
establishing
operating
ranges
for
parameters,
and
analyzing
point
by
point
applicability.
Monitor
related
refit,
calibration,
and
maintenance
activities
are
also
included
under
this
heading.

5)
Gather
Information,
Monitor,
and
Inspect
are
the
activities
involving
physical
inspections
of
equipment,
collection
of
monitored
data,
and
other
related
activities.

6)
Process/
Compile
and
Review
are
the
activities
that
involve
analysis
of
the
information
collected
for
accuracy
and
compliance
as
well
as
appropriate
records
and
reports
required
as
a
result.

7)
Complete
Reports
represents
the
activities
normally
associated
with
filling
out
forms.
Since
the
standard
requires
no
standard
forms,
these
activities
relate
to
the
preparing
of
formal
reports
and
cover
letters.

8)
Record/
Disclose
are
solely
recordkeeping
activities
which
occur
once
the
appropriate
report
information
has
been
extracted;
see
assumption
(
D).
These
activities
involve
software
translation,
duplication,
or
archival
processes
normally
associated
with
data
management
and
storage
common
to
this
industry.

9)
Store/
File
are
activities
which
are
solely
recordkeeping
which
occur
once
the
appropriate
report
information
has
been
extracted;
see
assumption
(
D).
These
activities
involve
the
management
life
cycle
of
records,
from
the
time
they
are
filed
and
boxed
up
to
the
time
they
are
disposed.

TOTAL
BURDEN
AND
COST
is
the
total
for
each
of
the
columns
(
d),
(
e),
(
f),
and
(
g).
F­
1
ATTACHMENT
F:
EPA
BURDEN
AND
COST
FOR
REFERENCING
SUBPARTS
TABLE
F.
1:
AVERAGE
ANNUAL
EPA
RESOURCE
REQUIREMENT
FOR
SUBPART
Kaa
Activity
(
A)

EPA/
hr
Occurrence
(
B)
Occurrences/

plant/
yr
(
C=
AxB)

EPA
hr/

plant/
yr
(
D)
Plants/

year
(
CxD)

EPA
hr/
yr
Report
Review:
New
Plant
Vapor
recoveryb
N/
A
Report
Review:
Existing
Plant
Notification
of
Reconstruction
2.0
1.0
2.0
0
0
Notification
of
Modification
2.0
1.0
2.0
0
0
Notification
of
seal
gap
measurement
0.5
1.0
0.5
174x0.9c
78
Report
of
gap
excesses
1.0
1.0
1.0
174x0.9c,
d
157
TOTAL
ANNUAL
HOURS
235
10%
Using
CAR
Rule
211
TOTAL
ANNUAL
COST
e
$
7775
aAssume
no
new
sources
subject
to
this
regulation.
All
similar
new
sources
will
be
subject
to
Subpart
Kb.

bRequired
only
at
start
of
construction.
Any
new
storage
vessel
being
constructed
would
be
subject
to
the
NSPS
Subpart
Kb.

cAssume
that
90%
of
the
storage
vessels
will
use
a
floating
roof.
The
remaining
10%
will
use
a
closed
vent
system.

dEach
respondent
is
assumed
to
manage
approximately
50
tanks
subject
to
Subpart
Ka.
Assume
that
a
number
of
the
average
50
tanks
per
respondent
using
a
floating
roof
will
have
excessive
seal
gaps
requiring
that
a
single
report
be
filed
once
per
year.

eAssume
a
labor
rate
to
be
GS­
10,
step
1@$
17.75x110%=$
36.85
per
FY
2001
Pay
Schedule
excluding
locality
pay.
F­
2
TABLE
F.
2:
AVERAGE
ANNUAL
EPA
RESOURCE
REQUIREMENT
FOR
SUBPART
Kb
Reporting
and
Recordkeeping
Requirements
Assumptionsa
Hours
$
b
1)
Review
notification
of
construction.
37b
new
notifications
at
2
hours
each
74
2,727
2)
Review
notice
of
anticipated
startup.
37
new
notifications
at
1
hour
each
37
1,363
3)
Review
notice
of
actual
startup.
37
new
notifications
at
1
hour
each
37
1,363
4)
Review
notification
of
initial
inspection
35
1,290
5)
Review
of
IFR
Failure
Reportc
55
2,027
6)
Review
Notification
of
Delay
for
Repair/
Emptying
IFR
67
2,469
7)
Review
Notification
to
Re­
Fill
602
22,184
TOTAL
ESTIMATED
HOURS
AND
COST
907
$
33,423
aDirect
personnel
costs
are
based
on
$
17.55
(
GS­
10,
Step
1)
per
hour
plus
110
percent
overhead
($
36.85)
multiplied
by
hours.

bAssume
111
new
storage
tanks
will
be
constructed
during
each
of
the
next
three
years,
or
37
tanks
per
year
(
28
IFR's,
7
EFR's,
2
CVS).

cOne
percent
failure
rate
for
the
5468
IFRs
choosing
annual
visual
inspections
equals
approximately
55.
F­
3
TABLE
F.
3:
AVERAGE
ANNUAL
EPA
RESOURCE
REQUIREMENT
FOR
SUBPART
VV
Activity
(
A)

EPA/
hr
Occurrence
(
B)
Occurrences/

plant/
yr
(
C)
a
EPA
hr/
plant/
yr
(
D)

Plants/
year
(
E)
b
EPA
hr/
yr
Monitoring
Emission
Tests
Initial
Performance
2
1
2
84
168
Repeat
Testc
1
1
1
17
17
Report
Review
New
Plant
0
Notification
of
Construction
18483
1
8
56d
448
Notification
of
Reconstruction/
Modification
2
1
2
28
56
Notification
of
Anticipated
Startup
0.5
1
0.5
84d
42
Notification
of
Actual
Startup
0.5
1
0.5
84
42
Notification
of
Initial
Test
0.5
1
0.5
101c
51
Review
Test
Results
2
1
2
101c
202
Existing
Plants
Semiannual
Emission
Reportse
2
2
4
1120
4480
TOTAL
ANNUAL
HOURS
5506
ANNUAL
COSTf
$
222,037
TOTAL
EXPENSES
(
1
person
x
84
sources/
yr
x
1
d/
source
x
$
50
per
diem)+($
250
roundtrip/
source
x
84
sources/
yr
=
$
25,284
TOTAL
ANNUAL
COST
$
247,321
aAxB=
C
bCxD=
E
cAssume
20
percent
of
initial
performance
test
must
be
repeated
due
to
failure.

dEstimate
that
there
are
84
new
affected
sources
(
56
new
affected
sources
will
be
due
to
construction
and
28
will
be
reconstructed
or
modified).

eThere
are
an
average
of
1120
sources
over
each
of
the
next
three
years.
These
sources
do
not
include
those
subject
to
both
Subpart
VV
and
the
HON,
which
are
assumed
to
be
complying
with
the
HON.

fEstimate
an
hourly
wage
of
$
25.21
plus
60%
overhead
expenses
which
equals
$
40.33.
This
amount
was
multiplied
by
the
total
of
hours
Column
E
to
estimate
the
total
annual
cost.
F­
4
TABLE
F.
4:
ANNUAL
AVERAGE
EPA
RESOURCE
REQUIREMENT
FOR
SUBPART
DDD
Activity
(
A)

EPA
hr/
Occurrence
(
B)
Occurrences
plant/
yr
(
C)
a
EPA
hr/

plant/
yr
(
D)

plants/
year
(
E)
b
EPA
hrs/
yr
(
F)
c
Cost/
yr
($)

Initial
Performance
Test
80
0.1d
8
10
80
3,226
Repeat
test
80
0.1d
8
2e
16
645
Report
Review
Notification
of
Construction/

Reconstruction/
Modification
2
1
2
10
20
807
Notification
of
Anticipated
Startup
2
1
2
10
20
807
Notification
of
Actual
Startup
2
1
2
10
20
807
Initial
Performance
Test
8
1
8
10
80
3,226
Repeat
Performance
Test
8
1
8
2
16
645
Semiannual
Reports
2
2
4
90f
360
14,519
TOTAL
ANNUAL
HOURS/
DIRECT
PERSONNEL
COST
612
24,682
TRAVEL
EXPENSESg
(
1
person
x
1.2
sources/
yr
x
2
days/
source
x
$
75.00
per
diem
+
($
250
RT/
source
x
1.2
sources/
yr
=
480
TOTAL
ANNUAL
COST
25,162
aAxB=
C
bCxD=
E
cAssume
hourly
wage
of
$
25.21
plus
60%
overhead
and
benefits
or
$
40.33
per
hour.

dAssume
EPA
personnel
attend
10
percent
of
tests.

eAssume
20
percent
of
performance
tests
are
repeated
due
to
failure
(.
2x10=
2).

fAverage
number
of
affected
sources
over
next
three
years.

gAssume
EPA
personnel
attend
10
percent
of
initial
tests
plus
10
percent
of
repeat
tests
(.
1x10)+(.
1x2)=
1.2.
F­
5
TABLE
F.
5:
AVERAGE
ANNUAL
EPA
RESOURCE
REQUIREMENT
FOR
SUBPART
III
Activity
(
A)

EPA
hr./
Occurrence
(
B)
Occurrences/
pla
nt/
yr
(
C)
a
EPA
hr/

plant/
yr
(
D)
Plants/
ye
ar
(
E)
b
EPA
hr/
yr
(
F)
c
EPA
Cost
($)

Monitoring
Emission
Test
Initial
Performance
Test
80
0.1d
8
1
8.00
323
Repeat
test
80
0.1
8
0.2e
1.60
65
Report
Review
New
Plant
­
Notification
of
Construction/
Reconstruction/
Modification
2
1
2
1
2.00
81
Notification
of
Anticipated
Startup
2
1
2
1
2.00
81
Notification
of
Actual
Startup
2
1
2
1
2.00
81
Initial
Test
8
1
8
1
8.00
323
Repeat
Performance
Test
8
1
8
0.2
1.60
65
Semiannual
Reports
2
2
4
11f
44.00
1,775
TOTAL
ANNUAL
HOURS/
DIRECT
PERSONNEL
COST
69.2
2,794
TRAVEL
EXPENSESg
(
1
person
x
0.12
sources/
yr
x
2
days/
source
x
$
50
per
diem)+
($
250
RT/
source
x
0.12
sources/
yr)
=
42
TOTAL
ANNUAL
COST
$
2,836
aAxB=
C
bCxD=
E
cAssume
hourly
wage
of
$
25.21
plus
60%
overhead
or
$
40.33
per
hour.

dAssume
EPA
personnel
attend
10
percent
of
tests.

eAssume
20
percent
of
performance
tests
are
repeated
due
to
failure
(.
2x1=
0.2).

fAverage
number
of
affected
sources
over
next
three
years.
Does
not
include
sources
subject
to
both
Subpart
III
and
the
HON,
which
are
assumed
to
be
complying
with
the
HON.

gAssume
EPA
personnel
attend
10
percent
of
initial
tests
plus
10
percent
of
repeat
tests
(.
1x1)+(.
1x.
2)=
0.12.
F­
6
TABLE
F.
6:
AVERAGE
ANNUAL
EPA
RESOURCE
REQUIREMENT
FOR
SUBPART
NNN
Activity
(
A)

EPA
hr./
Occurrence
(
B)
Occurrences/
pla
nt/
yr
(
C)
a
EPA
hr/

plant/
yr
(
D)
Plants/
ye
ar
(
E)
b
EPA
hr/
yr
(
F)
c
EPA
Cost
($)

Monitoring
Emission
Test
Initial
Performance
Test
80
0.1d
8
177
1,416
57,107
Repeat
test
80
0.1
8
35
280
11,292
Report
Review
New
Plant
­
Notification
of
Construction/
Reconstruction/
Modification
2
1
2
177
354
14,277
Notification
of
Anticipated
Startup
2
1
2
177
354
14,277
Notification
of
Actual
Startup
2
1
2
177
354
14,277
Initial
Test
8
1
8
177
1,416
57,107
Repeat
Performance
Test
8
1
8
35
280
11,292
Semiannual
Reports
2
2
4
1,345f
5,380
216,975
TOTAL
ANNUAL
HOURS/
DIRECT
PERSONNEL
COSTS
9,834
396,604
TRAVEL
EXPENSESg
(
1
person
x
21.2
sources/
yr
x
2
days/
source
x
$
50
per
diem)+
($
250
RT/
source
x
21.2
sources/
yr)
=
5,300
TOTAL
ANNUAL
COST
$
401,904
aAxB=
C
bCxD=
E
cAssume
hourly
wage
of
$
25.21
plus
60%
overhead
and
benefits
or
$
40.33
per
hour.

dAssume
EPA
personnel
attend
10
percent
of
tests.

eAssume
20
percent
of
performance
tests
are
repeated
due
to
failure
(.
2x177=
35).
The
original
ICR
indicated
that
2
plants
would
prepare
reports
for
repeat
performance
tests.

fAverage
number
of
affected
sources
over
next
three
years.
Does
not
include
sources
subject
to
both
Subpart
NNN
and
the
HON,
which
are
assumed
to
be
complying
with
the
HON.

gAssume
EPA
personnel
attend
10
percent
of
initial
tests
plus
10
percent
of
repeat
tests
(.
1x177)+(.
1x35)=
21.2.
F­
7
TABLE
F.
7:
AVERAGE
ANNUAL
EPA
RESOURCE
REQUIREMENT
FOR
SUBPART
RRR
Activity
(
A)

EPA
hr/
Occurrence
(
B)
Occurrences
plant/
yr
(
C)
a
EPA
hr/

plant/
yr
(
D)

plants/
yea
r
(
E)
b
EPA
hrs/
yr
(
F)
c
Cost/
yr
($)

Initial
Performance
Test
80
0.1d
8
20
160
6,453
Repeat
test
80
0.1
8
4e
32
1,291
Report
Review
Notification
of
Construction/

Reconstruction/
Modification
2
1
2
20
40
1,613
Notification
of
Anticipated
Startup
2
1
2
20
40
1,613
Notification
of
Actual
Startup
2
1
2
20
40
1,613
Initial
Performance
Test
8
1
8
20
160
6,453
Repeat
Performance
Test
8
1
8
4e
32
1,291
Semiannual
Reports
2
2
4
155f
620
25,005
TOTAL
ANNUAL
HOURS/
DIRECT
PERSONNEL
COST
1,124
45,332
TRAVEL
EXPENSESg
(
1
person
x
2.4
sources/
yr
x
2
days/
source
x
$
50.00
per
diem
+
($
250
RT/
source
x
2.4
sources/
yr
=
840
TOTAL
ANNUAL
COST
$
46,172
aAxB=
C
bCxD=
E
cAssume
hourly
wage
of
$
25.21
plus
60%
overhead
and
benefits
or
$
40.33
per
hour.

dAssume
EPA
personnel
attend
10
percent
of
tests.

eAssume
20
percent
of
performance
tests
are
repeated
due
to
failure
(.
2x20=
4).

fAverage
number
of
affected
sources
over
next
three
years.
Does
not
include
sources
subject
to
both
Subpart
RRR
and
the
HON,
which
are
assumed
to
be
complying
with
the
HON.

gAssume
EPA
personnel
attend
10
percent
of
initial
tests
plus
10
percent
of
repeat
tests
(.
1x20)+(.
1x4)=
2.4.
F­
8
TABLE
F.
8:
AVERAGE
ANNUAL
EPA
RESOURCE
REQUIREMENT
FOR
SUBPART
BB
Activity
(
A)

EPA/
hr
Occurrence
(
B)
Occurrences/

plant/
yr
(
C)
a
EPA
hr/
plant/
yr
(
D)
b
Plants/
year
(
E)
c
EPA
hr/
yr
Initial
Performance
Tests
New
Plantd
10
0
0
0
0
Repeat
Performance
Tests
New
Plantd
4
0
0
0
0
New
Plantd
Notification
of
construction
0.5
0
0
0
0
Notification
of
anticipated
startup
0.5
0
0
0
0
Notification
of
actual
startup
0.5
0
0
0
Initial
report
8
0
0
0
0
Notification
of
emission
test
0.5
0
0
0
0
Result
of
emission
test
4
0
0
0
0
Notification
of
performance
test
0.5
0
0
0
0
Result
of
performance
test
8
0
0
0
0
Review
test
results
8
0
0
0
0
Existing
Plant
Quarterly
reports
2
4
3.2
54
173
TOTAL
ANNUAL
HOURS
173
F­
9
ANNUAL
COST
$
6,977
TRAVEL
EXPENSESd
(
1
person
x
0
plants/
yr
x
3
d/
plant
x
$
50
per
diem)
+
($
250
round
trip/
source
x
0
sources/
yr
=$
0.00/
yr
0
TOTAL
ANNUAL
COSTe
$
6,977
aAxB=
C
bAssume
an
estimated
total
of
81
facilities.
Assume
2/
3
(
54)
facilities
are
marine
vessel
loading
facilities
and
must
continue
to
comply
with
this
Subpart;

assume
2
of
these
54
marine
vessel
loading
facilities
also
load
tank
trucks
and
railcars
that
are
not
subject
to
the
HON.

cCxD=
E
dAssume
no
new
sources.

eAssume
an
hourly
wage
of
a
GS­
12
step
1
employee
rate
(
25.21
plus
60%
for
overhead
and
benefit
costs
which
equals
40.33).
F­
10
TABLE
F.
9:
AVERAGE
ANNUAL
EPA
RESOURCE
REQUIREMENT
FOR
SUBPART
Y
Activity
(
A)

EPA/
hr
Occurrence
(
B)
Occurrences/

plant/
yr
(
C)

EPA
hr/

plant/
yr
(
D)
a
Plants/
year
(
E)
EPA
hr/
yr
(
F)
Cost/
yrb
Initial
Performance
Tests
New
Plant
N/
A
N/
A
N/
A
N/
A
N/
A
N/
A
Report
Review
New
Sources
Notification
of
construction
Included
in
NSPS
Kb
Notification
of
anticipated
startup
Included
in
NSPS
Kb
Notification
of
actual
startup
Included
in
NSPS
Kb
Notification
of
performance
test
N/
A
N/
A
N/
A
N/
A
N/
A
N/
A
Report
of
performance
test
N/
A
N/
A
N/
A
N/
A
N/
A
N/
A
Notification
of
control
installation
and
refill
at
1st
degassingc
1
1
1
14
14
672
Existing
Plant
Annual
IFR
internal
inspections
and
EFR
seal
gap
measurements
2
1
2
126
252
12096
Supplemental
delay
reportd
1
1
1
2.5
2.5
121
Quarterly
emission
reportse
N/
A
N/
A
N/
A
N/
A
N/
A
N/
A
TOTAL
ANNUAL
HOURS
AND
COST
268.5
12,889
F­
11
TRAVEL
EXPENSESc
1
person
x
14
plants/
yrc
x
1
d/
plant
x
$
50
per
diem)
+
($
250
round
trip/
plant
x
0
plants/
yr)
4,214
Total
$
17,103
aEstimate
that
there
are
126
existing
sources.
All
new
source
burden
is
included
in
the
NSPS
Subpart
Kb
regulation
for
storage
vessels
at
40
CFR
Part
60.

bEstimate
an
hourly
wage
of
$
22.86
plus
110%
overhead
expenses
which
equals
$
48.
This
amount
was
multiplied
by
the
hours
in
each
line
of
Column
E
to
estimate
the
total
annual
cost
per
year.

Estimate
that
one­
third
(
42)
of
existing
vessels
(
126)
will
be
degassed
over
the
next
three
years
(
equaling
14
sources
each
year)
and
comply
with
the
control
requirements.
This
first
renewal,
in
combination
with
the
original
estimates,
would
account
for
two­
thirds
and
leave
the
remaining
one­
third
of
existing
vessels
to
be
degassed
during
the
next
three­
year
renewal
period
to
meet
the
requirement
that
all
be
completed
within
ten
years.

dEstimate
that
two
percent
of
existing
sources
will
request
delay
of
repair
in
the
annual
report.

eAssume
that
no
source
will
select
the
fixed
roof
vented
to
a
control
device
option
and
thus
have
no
quarterly
report
of
excess
emissions.
F­
12
TABLE
F.
10:
AVERAGE
ANNUAL
EPA
RESOURCE
REQUIREMENT
FOR
SUBPART
V
Activity
(
A)

EPA/
hr
Occurrence
(
B)
Occurrences/

process
unit/
yr
(
C)
a
EPA
hr/
process
unit/
yr
(
D)

Process
units/
year
(
E)
b
EPA
hr/
yr
Initial
Performance
Tests
New
Plant
10
0
0.00
0c
0
Repeat
Performance
Test
New
Plantd
4
0
0.00
0
0
New
Plant
Notification
of
Construction
0.5
0
0.00
0
0
Notification
of
Anticipated
Startup
0.5
0
0.00
0
0
Notification
of
Actual
Startup
0.5
0
0.00
0
0
Notification
of
Test
0.5
0
0.00
0
0
Review
Test
Results
8
0
0.00
0
0
Review
Semiannual
Reports
for
existing
new
sources
2
4
8.00
81
648
TOTAL
ANNUAL
HOURS
648
ANNUAL
COSTe
TOTAL
EXPENSES
(
1
person
x
0
plants/
yr
x
3
d/
plant
x
$
50
per
diem)
+
($
250
round
trip/
plant
x
0
plants/
yr
=

TOTAL
ANNUAL
COST
$
23,957
aAxB=
C
bCxD=
E
cAssume
no
new
process
units
per
year
and
81
existing
process
units
subject
to
NESHAP
V,
but
not
the
HON.

dAssume
20
percent
of
initial
performance
test
must
be
repeated
due
to
failure.

eEstimate
an
hourly
wage
of
$
36.97
(
GS­
12,
step
1
23.11x1.6%
overhead)
This
amount
was
multiplied
by
the
total
of
hours
Column
E
to
estimate
the
total
annual
cost.
F­
13
TABLE
F.
11:
AVERAGE
ANNUAL
EPA
RESOURCE
REQUIREMENT
FOR
SUBPARTS
F,
G,
H,
and
I
Burden
Item
Average
Hours
per
Activity
(
a)
Number
of
Activities
per
Year
(
b)
Estimated
Technical
Hours
per
year
(
c)
Estimated
Managerial
Hours
per
year
(
d)
Estimated
Clerical
Hours
per
year
(
e)
Annual
Cost
in
$
Thousands
per
year
(
f)

PERFORMANCE
TESTS:

1)
Initial
40
4
160
8
16
7
2)
Repeat
40
1
40
2
4
2
REPORTS
REVIEW:

1)
Initial
2
5
10
1
1
0.5
2)
Implementation
Plan
or
Permit
20
5
100
5
10
4.6
3)
Compliance
status
40
5
200
10
20
9.1
4)
Review
equipment
leak
monitoring
7
480
3,360
168
336
153.2
5)
Notification
of
Construction/
Reconstruction.
2
5
10
1
1
0.5
6)
Notification
of
anticipated
startup
2
5
10
1
1
0.5
7)
Notification
of
actual
startup
2
5
10
1
1
0.5
8)
Notification
of
Performance
Test
2
5
10
1
1
0.5
9)
Review
of
test
results
8
5
40
2
4
1.8
10)
Review
periodic
reports
4
640
2,560
128
256
116.7
TOTAL
BURDEN
AND
COST
(
Salary)
6,510
326
651
297
TRAVEL
EXPENSES
5
TOTAL
ANNUAL
COST
302
F­
14
See
Attachment
H
for
assumptions
and
further
description
of
activities.
G­
1
ATTACHMENT
G:
RESPONDENT
BURDEN
AND
COST
FOR
REFERENCING
SUBPARTS
TABLE
G.
1:
ANNUAL
BURDEN
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
FOR
SUBPART
Kaa
(
A)

hr/
Occurrence
(
B)
Occurrences/

plant/
yr
(
C=
AxB)

hr/
plant/
yr
(
D)
a
Plants/
year
(
E=
CxD)

hr/
yr
(
F)
Cost/
yrb
1.
Applications
N/
A
2.
Surveys
and
Studies
N/
A
3.
Reporting
Requirements
A.
Read
Instruction
Included
in
3B
B.
Required
Activities
Vapor
recovery
information
20
1
20
0
0
0
Measure
seal
gap
Included
in
4E
C.
Create
Information
Included
in
3B
D.
Gather
Existing
Information
1
1
1
156.6c
157
7,790
E.
Write
Report
Notification
of
construction
2
1
2
0
0
0
Notification
of
anticipated
startup
2
1
2
0
0
0
Notification
of
actual
startup
2
1
2
0
0
0
Notification
of
gap
measurement
1.5
1
1.5
156.6c
235
11,661
(
A)

hr/
Occurrence
(
B)
Occurrences/

plant/
yr
(
C=
AxB)

hr/
plant/
yr
(
D)
a
Plants/
year
(
E=
CxD)

hr/
yr
(
F)
Cost/
yrb
G­
2
Report
of
seal
gap
excess
2.5
1
2.5
156.6c
392
19,451
Information
on
vapor
recovery
Included
in
3B.

4.
Recordkeeping
Requirements
A.
Read
Instructions
Included
in
3B.

B.
Plan
Activities
Included
in
3B
C.
Implement
Activities
Included
in
3B
D.
Develop
Record
System
N/
A
0
E.
Time
to
Enter
Information
0
New
tank
seal
gap
measurements
5x50
1
250
0
0
0
Secondary
seal
gap
measurement
5x50d,
e
1
250
156.6c
39,250
1,947,585
Primary
seal
gap
measurements
2x50d
0.2f
20
156.6c
3,140
155,807
Fill/
refill
record
.20x10g
1
2
174
314
15,581
F.
Train
Personnel
N/
A
0
G.
Audits
N/
A
0
TOTAL
ANNUAL
BURDEN
43,488
2,157,875
10%
Using
CAR
Rule
39,139
1,942,077
G­
3
aAssume
that
there
will
be
no
new
source
subject
to
the
requirements
of
this
regulation.
Similar
new
sources
will
be
subject
to
NSPS
Subpart
Kb.

bTechnical
Rate
based
on
U.
S.
Department
of
Labor,
Bureau
of
Labor
Statistics,
Employer
Costs
for
Employee
Compensation,
March
1999,
June
24,
1999.

Hourly
rate
for
professional
specialty
in
manufacturing
industry
($
23.63)
multiplied
by
110
percent
(
profit
and
overhead)
=
$
49.62/
hour.

cEstimate
that
10%
of
respondents
will
use
a
vapor
recovery
control
system
and
the
balance
(
90%)
will
use
a
floating
roof
system.
Respondents
using
vapor
recovery
control
are
not
required
to
do
seal
gap
measurements.

dThere
is
an
approximate
average
of
50
tanks
subject
to
Subpart
Ka
per
respondent.
Assume
that
a
number
of
tanks
per
every
respondent
using
a
floating
roof
will
have
excessive
seal
gaps
requiring
that
a
single
report
be
filed
once
a
year.

eEstimate
five
hours
to
conduct
secondary
seal
measurements
annually
for
an
average
50
tanks
per
respondent.

fEstimate
two
hours
to
conduct
primary
seal
measurements
every
five
years.

gAssume
that
any
one
tank
would
be
emptied
on
average
once
every
five
years,
and
then
required
to
report
a
liquid
change.
During
any
one
year,
a
respondent
would
change
liquid
in
approximately
10
tanks
or
20%
of
the
50
tank
average
at
each
facility.

Notifications:

1.
90%
of
respondents
will
notify
yearly
on
secondary
seal
gap
measurements
taking
place
157
2.
3%
of
157
notifications
will
need
to
report
secondary
seal
gap
exceedance
5
3.
For
primary
gap
measures,
20%
of
respondents
will
conduct
31
4.
Of
the
31
respondents,
1%
will
need
to
report
exceeding
any
primary
seal
gap.
1
5.
20%
of
respondents
will
notify
that
they
are
fill/
refill
storage
vessels
31
­­­­­­­

Total
number
of
annual
responses
(
Block
13b)
225
G­
4
TABLE
G.
2:
ANNUAL
BURDEN
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
FOR
SUBPART
Kb
(
A)

hr/
Occurrence
(
B)
Occurrences/

plant/
yr
(
C=
AxB)

hr/
plant/
yr
(
D)
a
Plants/
year
(
E=
CxD)

hr/
yr
(
F)
Cost/
yrb
1.
Applications
N/
A
2.
Surveys
and
Studies
N/
A
3.
Reporting
Requirements
A.
Read
Instruction
1
1
1
37d
37
1,836
B.
Required
Activities
One­
Time
Only
Requirements
Notification
of
Start
of
Construction
2
1
2
37
74
3,672
Notification
of
Anticipated
Startup
Date
2
1
2
37
74
3,672
Notification
of
Actual
Startup
2
1
2
37
74
3,672
Notification
of
Physical
or
Operational
Changesc
N/
A
Notification
of
Malfunctionc
N/
A
Notification
of
Initial
Inspection
IFR
Internal
Inspection
2
1
2
28
56
2,779
EFR
Gap
Measurement
2
1
2
7
14
695
Initial
Inspection
0
IFR
Internal
Inspection
12
1
12
28d
336
16,672
EFR
2nd
Seal
Gap
Measure
8
1
8
7
56
2,779
(
A)

hr/
Occurrence
(
B)
Occurrences/

plant/
yr
(
C=
AxB)

hr/
plant/
yr
(
D)
a
Plants/
year
(
E=
CxD)

hr/
yr
(
F)
Cost/
yrb
G­
5
EFR
1st
Seal
Gap
Measure
12
1
12
7
84
4,168
CVS
Operating
Plan
8
1
8
2
16
794
Repeat
Requirements
Internal
IFR
Inspectione
12
1
12
116
1,392
69,071
Visual
IFR
Inspectione
8
1
8
463
3,704
183,792
Report
of
IFR
Failuref
2
1
2
55
110
5,458
Notification
of
Delay
of
Repair
or
Emptying
for
IFRg
4
1
4
67
268
13,298
EFR
2nd
Seal
Gap
Measure
8
1
8
580
4,640
230,237
EFR
1st
Seal
Gap
Measure
12
1
12
580
6,960
345,355
Notification
of
Refillh
2
1
2
602
1,204
59,742
Total
Annual
Responses
(
Block
13b)
1270i
4.
RECORDKEEPING
REQUIREMENTS
A.
Read
Instructions
1
1
1
37
37.00
1,836
B.
Gather
and
Record
Information
i.
Vessel
Volumes,
Liquid
Vapor
Pressure,
flares
8
1
8
580
4,640.00
230,237
ii.
113b(
a)
inspection
12
1
12
580
6,960.00
345,355
iii.
113b(
b)
gap
measurement
12
1
12
580
6,960.00
345,355
C.
Develop
Record
System
10
1
10
3
30.00
1,489
(
A)

hr/
Occurrence
(
B)
Occurrences/

plant/
yr
(
C=
AxB)

hr/
plant/
yr
(
D)
a
Plants/
year
(
E=
CxD)

hr/
yr
(
F)
Cost/
yrb
G­
6
D.
Time
to
Enter
Information
­
CVS
Parameter
Records
2
52
104
355
36,920.00
1,831,970
F.
Train
Personnel
N/
A
G.
Audits
N/
A
SUBTOTAL
ESTIMATED
REPORTING
HOURS
74,646
SUBTOTAL
ESTIMATED
REPORTING
COST
3,703,934
aEstimate
that
there
are
580
existing
respondents
with
an
average
of
7,254
regulated
vessels
in
service
over
the
next
three
years.
Estimate
that
75
percent
(
5468)
of
vessels
have
IFR
and
20
percent
(
1458)
have
EFR
and
5
percent
(
355)
have
closed­
vent
control
systems.
This
does
not
include
sources
subject
to
both
Subpart
Kb
and
the
HON,
which
are
assumed
to
be
complying
with
the
HON.

bAssume
an
hourly
wage
of
$
23.63
plus
110
percent
overhead
and
profit
which
equals
$
49.62
This
was
multiplied
by
the
number
in
column
E
to
estimate
cost
per
year.

cThe
General
Provision
notifications
of
modification
or
malfunction
will
be
covered
by
notification
within
the
subpart.

dAssume
that
there
will
be
37
new
respondents
each
of
the
next
three
years,
which
includes
28
IFR
and
7
EFR
and
2
CVS.

eFor
each
of
the
5,468
IFRs
at
580
respondents,
eighty
(
80)
percent
(
464)
will
conduct
an
annual
visual
inspection,
and
20
percent
(
116)
will
conduct
an
internal
inspection.

fOne
percent
failure
rate
for
the
5468
IFRs
choosing
annual
visual
inspections
equals
approximately
55.

gTen
percent
of
55
failed
IFRs
are
delayed
in
repair
or
emptying
equals
approximately
6.

hAssume
that
all
5,468
IFR
tanks
will
be
routinely
serviced
through
a
shutdown
and
degassed
once
every
ten
years.
One
tenth
the
5468
IFR
will
be
degassed
each
year
for
an
annual
average
of
547
per
year.
This
number
was
added
to
the
estimated
55
visual
inspection
failures
that
would
lead
to
internal
inspections
for
a
total
estimate
of
602
notices
of
refill.

iThe
number
of
responses
was
determined
by
adding
Notifications,
Reports
and
Records
and
then
subtracting
out
those
who
report
and
those
who
keep
records
without
reporting.

Notifications/
year
815
Reports
55
Recordkeeping
580
Total
1450
Subtract
from
the
580
those
who
had
to
file
a
report
or
notification.
Assume
55
IFR
reports,
each
a
separate
response.
Assume
67
Notification
of
delay
for
repair
or
emptying
of
IFR,
each
a
separate
company
different
than
55
IFR
reports.
Assume
10%
of
the
580
for
notification
of
refill
­
58.
Total
of
180
to
be
subtracted
from
1450
for
a
total
of
1270.
G­
7
TABLE
G.
3:
ANNUAL
BURDEN
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
FOR
SUBPART
VV
Activity
(
A)
Hours/
Occurrence
(
B)
Occurrences/

respondent/

year
(
C=
AXB)

Hours/
respondent/

year
(
D)
a
Respondents/
year
(
E=
CXD)

Hours/
yr
(
F)
b
Cost/
year
1.
Applications
N/
A
2.
Survey
and
Studies
N/
A
3.
Reporting
Requirements
A.
Read
Instructions
1
1
1
84
84
4,615
B.
Required
Activities
Initial
Performance
Test
48
1
48
84
4,032
221,518
Repeat
Performance
Test
48
1
48
17c
816
44,831
C.
Create
Information
Included
in
3B
D.
Gather
Existing
Information
Included
in
3E
E.
Write
Report
New
Sources
Notification
of
Construction
2
1
2
56
112
6,153
Notification
of
Reconstruction/
Modification
2
1
2
28
56
3,077
Notification
of
Anticipated
Startup
2
1
2
84
168
9,230
Notification
of
Actual
Startup
2
1
2
84
168
9,230
Notification
of
Initial
Performance
Test
2
1
2
101
202
11,098
Report
of
Performance
Test
Included
in
3B
Activity
(
A)
Hours/
Occurrence
(
B)
Occurrences/

respondent/

year
(
C=
AXB)

Hours/
respondent/

year
(
D)
a
Respondents/
year
(
E=
CXD)

Hours/
yr
(
F)
b
Cost/
year
G­
8
Existing
Sources
Semiannual
Report
4
2
8
1,120
8,960
492,262
Total
Annual
Responses
(
Block
13b)
2593
SUBTOTAL
14,598
802,014
4.
Recordkeeping
Requirements
A.
Read
Instructions
Included
in
3A
B.
Plan
Activities
Included
in
4C
C.
Implement
Activities
Included
in
3B
D.
Develop
Record
System
N/
A
E.
Time
to
Enter
Information
Records
of
Operating
Parameters
80
1
80
1,120
89,600
4,922,624
F.
Train
personnel
N/
A
G.
Audits
N/
A
TOTAL
ANNUAL
BURDEN
104,198
5,724,638
aAssume
that
there
will
be
an
average
84
new,
modified
or
reconstructed
facilities
each
year
over
the
next
3
years.
Estimate
that
56
of
new
affected
sources
will
be
due
to
construction
and
28
will
be
reconstructed
or
modified.
There
are
estimated
to
be
an
annual
average
of
1120
affected
sources
over
each
of
the
next
three
years.
This
does
not
include
sources
subject
to
both
Subpart
VV
and
the
HON,
which
are
assumed
to
be
complying
with
the
HON.

bAssume
an
hourly
wage
of
$
26.16
plus
110%
overhead
and
profit
or
$
54.94
per
hour.
This
amount
was
multiplied
by
the
hours
per
year
in
Column
E.

cAssume
20%
of
initial
performance
tests
must
be
repeated
due
to
failure.
G­
9
TABLE
G.
4:
ANNUAL
BURDEN
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
FOR
SUBPART
DDD
Activity
(
A)

Hours
per
Occurrence
(
B)
Occurrences/

respondent/

year
(
C)
a
Hours/
respondent/

year
(
D)
Respondents/
year
(
E)

Hours/
year
(
CXD)
(
F)
b
Cost/
year
($)

1.
Applications
N/
A
2.
Survey
and
Studies
N/
A
3.
Reporting
Requirements
A.
Read
Instructions
1
1
1
10
c
10
549
B.
Required
Activities
Initial
Performance
Test
360
1
360
10
3,600
197,784
Repeat
Performance
Test
360
1
360
2d
720
39,557
C.
Write
Report
Notification
of
Construction/
Modification
2
1
2
10
20
1,099
Notification
of
Anticipated
Startup
2
1
2
10
20
1,099
Notification
of
Actual
Startup
1
1
1
10
10
549
Notification
of
Initial
Performance
Test
2
1
2
10
20
1,099
Semiannual
Report
3
2
6
90e
540
29,668
Total
Annual
Responses
(
Block
13b)
220
4.
Recordkeeping
Requirements
Activity
(
A)

Hours
per
Occurrence
(
B)
Occurrences/

respondent/

year
(
C)
a
Hours/
respondent/

year
(
D)
Respondents/
year
(
E)

Hours/
year
(
CXD)
(
F)
b
Cost/
year
($)

G­
10
Record
of
Operating
Parameters
for
Control
Devices
18f
1
8
10
80
4,395
Records
of
Operating
Conditions
Exceeding
Last
Performance
Test
8
1
8
90
720
39,557
Records
of
Startup,
Shutdown,

Malfunction,
etc.
1.5
50
75
90
6,750
370,845
TOTAL
ANNUAL
BURDEN
12,490
686,201
aAxB=
C
bAssume
hourly
wage
of
$
26.16
plus
110%
overhead
and
profit
or
$
54.94
per
hour.

cAssume
10
new
affected
sources
per
year.

dAssume
20
percent
of
performance
tests
are
repeated
due
to
failure.
(.
2
x
10
=
2)

eAverage
number
of
affected
sources
over
next
three
years.
G­
11
TABLE
G.
5
ANNUAL
BURDEN
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
FOR
SUBPART
III
Activity
(
A)

Hours
per
Occurrence
(
B)
Occurrences/

respondent/

year
(
C)
a
Hours/
respondent/

year
(
D)
Respondents/
year
(
E)
Hours/
yr
(
E­
CXD)
(
F)
b
Cost/
yr
($)

1.
Applications
N/
A
2.
Survey
and
Studies
N/
A
3.
Reporting
Requirements
A.
Read
Instructions
1
1
1
1
c
1
55
B.
Required
Activities
Initial
Performance
Test
60
1
60
1
60
3,296
Repeat
Performance
Test
60
1
60
0d
0
0
C.
Write
Report
Notification
of
Construction/
Modification
2
1
2
1
2
110
Notification
of
Anticipated
Startup
2
1
2
1
2
110
Notification
of
Actual
Startup
1
0
1
1
1
55
Notification
of
Initial
Performance
Test
2
1
2
1
2
110
Semiannual
Report
3
2
6
11e
66
3,626
Total
Annual
Responses
(
Block
13b)
25
4.
Recordkeeping
Requirements
Activity
(
A)

Hours
per
Occurrence
(
B)
Occurrences/

respondent/

year
(
C)
a
Hours/
respondent/

year
(
D)
Respondents/
year
(
E)
Hours/
yr
(
E­
CXD)
(
F)
b
Cost/
yr
($)

G­
12
Record
of
Operating
Parameters
for
Control
Devices
8
1
8
1
8
440
Records
of
Operating
Conditions
Exceeding
Last
Performance
Test
8
1
8
11
88
4,835
Records
of
Startup,
Shutdown,

Malfunction,
etc.
1.5
50
75
11
825
45,326
TOTAL
ANNUAL
BURDEN
1,055
57,963
aAxB=
C
bAssume
hourly
wage
of
$
26.16
plus
110%
overhead
and
profit
or
$
54.94
per
hour
cAssume
1
new
affected
source
per
year
subject
to
Subpart
III
and
not
the
HON.

dAssume
20
percent
of
performance
tests
are
repeated
due
to
failure.
(.
2
x
1
=
0)

eAverage
number
of
affected
sources
over
next
three
years.
This
does
not
include
sources
subject
to
both
Subpart
III
and
the
HON,
which
are
assumed
to
be
complying
with
the
HON.
G­
13
TABLE
G.
6
ANNUAL
BURDEN
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
FOR
SUBPART
NNN
Activity
(
A)

Hours
per
Occurrence
(
B)
Occurrences/

respondent/

year
(
C)
a
Hours/
respondent/

year
(
D)
Respondents/
year
(
E)

Hours/
year
(
E­
CXD)
(
F)
b
Cost/
year
($)

1.
Applications
N/
A
2.
Survey
and
Studies
N/
A
3.
Reporting
Requirements
A.
Read
Instructions
1
1
1
177c
177
9,724
B.
Required
Activities
Initial
Performance
Test
60
1
60
177
10,620
583,463
Repeat
Performance
Test
60
1
60
35d
2,100
115,374
C.
Write
Report
Notification
of
Construction/
Modification
2
1
2
177
354
19,449
Notification
of
Anticipated
Startup
2
1
2
177
354
19,449
Notification
of
Actual
Startup
1
1
1
177
177
9,724
Notification
of
Initial
Performance
Test
2
1
2
177
354
19,449
Semiannual
Report
3
2
6
1,345
8,070
443,366
Total
Annual
Responses
(
Block
13b)
3398
4.
Recordkeeping
Requirements
Activity
(
A)

Hours
per
Occurrence
(
B)
Occurrences/

respondent/

year
(
C)
a
Hours/
respondent/

year
(
D)
Respondents/
year
(
E)

Hours/
year
(
E­
CXD)
(
F)
b
Cost/
year
($)

G­
14
Record
of
Operating
Parameters
for
Control
Devices
8
1
8
177
1,416
77,795
Records
of
Operating
Conditions
Exceeding
Last
Performance
Test
8
1
8
1,345
10,760
591,154
Records
of
Startup,
Shutdown,

Malfunction,
etc.
1.5
50
75
1,345
100,875
5,542,073
TOTAL
ANNUAL
BURDEN
135,257
7,431,020
aAxB=
C
bAssume
hourly
wage
of
$
26.16
plus
110%
overhead
and
profit
or
$
54.94
per
hour.

cAssume
177
new
affected
sources
per
year
subject
to
Subpart
NNN
and
not
the
HON.

dAssume
20
percent
of
performance
tests
are
repeated
due
to
failure.
(.
2
x
177
=
35)

eAverage
number
of
affected
sources
over
next
three
years.
This
does
not
include
sources
subject
to
both
Subpart
NNN
and
the
HON,
which
are
assumed
to
be
complying
with
the
HON.
G­
15
TABLE
G.
7
ANNUAL
BURDEN
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
FOR
SUBPART
RRR
Activity
(
A)

Hours
per
Occurrence
(
B)
Occurrences/

respondent/

year
(
C)
a
Hours/
respondent/

year
(
D)
Respondents/
year
(
E)

Hours/
year
(
E­
CXD)
(
F)
b
Cost/
year
($)

1.
Applications
N/
A
2.
Survey
and
Studies
N/
A
3.
Reporting
Requirements
A.
Read
Instructions
1
1
1
20
c
20
1,099
B.
Required
Activities
Initial
Performance
Test
60
1
60
20
1,200
65,928
Repeat
Performance
Test
60
1
60
4d
240
13,186
C.
Write
Report
Notification
of
Construction/
Modification
2
1
2
20
40
2,198
Notification
of
Anticipated
Startup
2
1
2
20
40
2,198
Notification
of
Actual
Startup
1
1
1
20
20
1,099
Notification
of
Initial
Performance
Test
2
1
2
20
40
2,198
Semiannual
Report
3
2
6
155e
930
51,094
Total
Annual
Responses
(
Block
13b)
390
4.
Recordkeeping
Requirements
Activity
(
A)

Hours
per
Occurrence
(
B)
Occurrences/

respondent/

year
(
C)
a
Hours/
respondent/

year
(
D)
Respondents/
year
(
E)

Hours/
year
(
E­
CXD)
(
F)
b
Cost/
year
($)

G­
16
Record
of
Operating
Parameters
for
Control
Devices
8
1
8
20
160
8,790
Records
of
Operating
Conditions
Exceeding
Last
Performance
Test
8
1
8
155
1,240
68,126
Records
of
Startup,
Shutdown,

Malfunction,
etc.
1.5
50
75
155
11,625
638,678
TOTAL
ANNUAL
BURDEN
15,555
854,594
aAxB=
C
bAssume
hourly
wage
of
$
26.16
plus
110%
overhead
and
profit
or
$
54.94
per
hour.

cAssume
20
new
affected
sources
per
year
subject
to
Subpart
RRR
and
not
the
HON.

dAssume
20
percent
of
performance
tests
are
repeated
due
to
failure.
(.
2
x
20
=
4)

eAverage
number
of
affected
sources
over
next
three
years.
This
does
not
include
sources
subject
to
both
Subpart
RRR
and
the
HON,
which
are
assumed
to
be
complying
with
the
HON.
G­
17
TABLE
G.
8
ANNUAL
BURDEN
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
FOR
SUBPART
BB
(
A)

hr/
Occurrence
(
B)
Occurrences/

Respondent/
yr
(
C=
AxB)

hr/
Respondent/
yr
(
D)
a
Respondent/

yr
(
E=
CxD)

hr/
yr
(
F)
Cost/
yrb
1.
Applications
Application
for
approval
of
Construction/

Modification
N/
A
2.
Surveys
and
Studies
N/
A
3.
Reporting
Requirements
A.
Read
Instruction
1
1
1
0
0
0
B.
Required
Activities
Initial
emission
test
20
0
20
0
0
0
Monitoring
performance
test
280
1
280
0
0
0
Vapor­
tightness
test
tank
truck
and
railcars
11
1
11
3c
33
1,813
Marine
vessels
80
1
80
66c
5,280
290,083
Closed
vent
leak
inspection
8
1
8
54c
432
23,734
C.
Create
Information
Included
in
3B
D.
Gather
Existing
Information
Included
in
3E
E.
Write
Report
Notification
of
anticipated
startup
2
0
0
0
0
0
Notification
of
actual
startup
2
0
0
0
0
0
Notification
of
emission
test
2
0
0
0
0
0
(
A)

hr/
Occurrence
(
B)
Occurrences/

Respondent/
yr
(
C=
AxB)

hr/
Respondent/
yr
(
D)
a
Respondent/

yr
(
E=
CxD)

hr/
yr
(
F)
Cost/
yrb
G­
18
Report
of
emission
test
8
0
0
0
0
0
Notification
of
performance
test
2
0
0
0
0
0
Report
of
performance
test
8
0
0
0
0
0
Report
facilities
below
cut­
off
d
8
0
0
0
0
0
Quarterly
parameter
excesses
4
4
6.7
54
362
19,888
Total
Annual
Responses
(
Block
13b)
216
SUBTOTAL
6,107
335,518
4.
Recordkeeping
Requirements
A.
Read
Instructions
Included
in
3A
B.
Plan
Activities
Included
in
4C
C.
Implement
Activities
Included
in
3B
D.
Develop
Record
System
N/
A
E.
Time
to
Enter
Information
Facilities
above
cut­
off
1.5
52
33
54
1,782
97,903
Facilities
below
cut­
offd
0.5
52
26
0
0
0
F.
Train
Personnel
N/
A
(
A)

hr/
Occurrence
(
B)
Occurrences/

Respondent/
yr
(
C=
AxB)

hr/
Respondent/
yr
(
D)
a
Respondent/

yr
(
E=
CxD)

hr/
yr
(
F)
Cost/
yrb
G­
19
G.
Audits
N/
A
Subtotal
(
recordkeeping)
1,782
97,903
TOTAL
ANNUAL
BURDEN
7,889
$
433,421
aExpect
that
there
will
be
no
new
sources
covered
by
these
standards
over
the
next
three
years.

bCost
is
based
upon
an
hourly
wage
of
$
26.16
plus
110
percent
overhead
and
profit
which
equals
$
54.94.
This
amount
was
multiplied
by
the
hours
per
year
in
column
E
to
get
the
cost
per
year.

cEstimate
that
there
are
54
facilities
subject
to
this
standard.
Estimate
there
are
3
tank
truck
and
railcars
and
131
marine
vessels
subject
to
the
standards.
All
other
transfer
racks
subject
to
Subpart
BB
are
assumed
to
be
complying
with
the
HON.
Assume
50%
of
the
marine
vessels
(
66)
operate
at
negative
pressure
and
do
not
conduct
annual
vapor­
tightness
tests.

dFor
sources
below
the
low
quantity
applicability
for
control
requirements,
a
report
is
only
required
the
first
year
of
operation.
It
is
assumed
that
this
report
has
been
submitted.
G­
20
TABLE
G.
9
ANNUAL
BURDEN
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
FOR
SUBPART
Y
(
A)

hr/
Occurrence
(
B)
Occurrences/

Respondent/
yr
(
C=
AxB)

hr/
Respondent/
yr
(
D)
a
Respondent/

yr
(
E=
CxD)

hr/
yr
(
F)
Cost/
yrb
1.
Applications
Application
for
approval
of
Construction/

Modification
N/
A
2.
Surveys
and
Studies
N/
A
3.
Reporting
Requirements
A.
Read
Instructions
Included
in
3C
B.
Required
Activities
Initial
performance
test
N/
A
C.
Create
Information
Included
in
3B
Existing
Sources
Annual
IFR
Internal
Inspections
and
EFR
Seal
Gap
measurements
8
1
8
4
32
1,758
D.
Gather
Existing
Information
Included
in
3C
E.
Write
Report
Notification
of
Construction/

Reconstruction
Included
in
NSPS
Kb
Notification
of
anticipated
startup
Included
in
NSPS
Kb
Notification
of
actual
startup
Included
in
NSPS
Kb
Notification
of
emission
test
N/
A
(
A)

hr/
Occurrence
(
B)
Occurrences/

Respondent/
yr
(
C=
AxB)

hr/
Respondent/
yr
(
D)
a
Respondent/

yr
(
E=
CxD)

hr/
yr
(
F)
Cost/
yrb
G­
21
Report
of
emission
test
N/
A
Notification
of
Control
installation
and
refill
at
1sy
IFR
Degassingc
Existing
Sources
Annual
Inspection
Reports
2
2
4
4
16
879
Supplemental
Delay
Reportd
2
1
2
0
0.2
11
Quarterly
Emission
Report
None
Expectede
SUBTOTAL
48.2
2,648
Total
Annual
Responses
(
Block
13b)
8
4.
Recordkeeping
Requirements
A.
Read
Instructions
Included
in
3A
B.
Plan
Activities
Included
in
4C
C.
Implement
Activities
Filing
and
Maintaining
Records
2
1
2
4
8
D.
Develop
Record
System
Included
in
4C
E.
Time
to
Enter
Information
Included
in
4C
F.
Train
Personnel
N/
A
G.
Audits
N/
A
(
A)

hr/
Occurrence
(
B)
Occurrences/

Respondent/
yr
(
C=
AxB)

hr/
Respondent/
yr
(
D)
a
Respondent/

yr
(
E=
CxD)

hr/
yr
(
F)
Cost/
yrb
G­
22
TOTAL
ANNUAL
BURDEN
56
3,088
aEstimate
that
there
will
be
4
existing
sources
not
covered
by
the
HON.
All
new
source
burden
is
included
in
the
NSPS
Subpart
Kb
regulation
for
storage
vessels
at
40
CFR
Part
60
bEstimate
an
hourly
wage
of
$
26.16
plus
110%
overhead
and
profit
which
equals
and
54.94.
This
amount
was
multiplied
by
the
hours
in
each
line
of
Column
E
to
estimate
the
total
annual
cost
per
year.

cIt
is
believed
that
all
vessels
have
been
degassed
and
all
controls
have
been
installed
as
they
were
to
be
installed
within
10
years
of
promulgation.

dEstimate
that
two
percent
of
existing
sources
will
request
delay
of
repair
in
the
annual
report.

eAssume
that
no
sources
will
select
the
fixed
roof
vented
to
a
control
device
option
and
thus
have
no
quarterly
reports
of
excess
emissions.

NOTE:
The
83­
I
also
includes
40
CFR
Part
61,
Subpart
L.
There
are
36
Subpart
L
sources
with
a
burden
of
7083
hours.
G­
23
TABLE
G.
10
ANNUAL
BURDEN
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
FOR
SUBPART
V
Activity
(
A)
Hours/
Occurrence
(
B)
Occurrences/

respondent/

year
(
C=
AXB)

Hours/
respondent/

year
(
D)
Respondents/
year
(
E=
CXD)

Hours/
yr
(
F)
a
Cost/
year
1.
Applications
N/
A
2.
Survey
and
Studies
N/
A
3.
Reporting
Requirements
A.
Read
Instructions
1
1
1
2b
2
111
B.
Required
Activities
Initial
Performance
Test
20
1
20
2
40
2,214
Reference
Method
21/
22
tests
4
1
4
2
8
443
Repeat
Performance
Test
20
0.2
4
2
8
443
C.
Create
Information
See
3B
D.
Gather
Existing
Information
See
3B
E.
Write
Report
Notification
of
Construction/

Reconstruction
2
1
2
2
4
221
Notification
of
Anticipated
Startup
2
1
2
2
4
221
Notification
of
Actual
Startup
2
1
2
2
4
221
Notification
of
Initial
Performance
Test
2
1
2
2
4
221
Report
of
Performance
Test
See
3B
Application
for
Alternative
10
1
10
0.5
5
277
Activity
(
A)
Hours/
Occurrence
(
B)
Occurrences/

respondent/

year
(
C=
AXB)

Hours/
respondent/

year
(
D)
Respondents/
year
(
E=
CXD)

Hours/
yr
(
F)
a
Cost/
year
G­
24
Initial
Report
8
1
8
2
16
885
Semiannual
Report
30
2
60
200c
12,000
664,080
Total
Annual
Responses
(
Block
13b)
411
SUBTOTAL
12,095
669,337
4.
Recordkeeping
Requirements
A.
Read
Instructions
See
3A
B.
Plan
Activities
See
4C
C.
Implement
Activities
See
3B
D.
Develop
Record
System
N/
A
E.
Time
to
Enter
Information
Records
of
startups,
shutdown,

malfunction,
etc.
1.5
1
1.5
2
3
166
Records
of
operating,

parameters
and
emissions
0.1
365d
36.5
200c
7,300
403,982
Records
of
leak
detected
0.4
52
20.8
200
4,160
230,214
F.
Train
personnel
N/
A
G.
Audits
N/
A
SUBTOTAL
11,463
634,362
TOTAL
ANNUAL
BURDEN
23,558
1,303,699
aAssume
an
hourly
wage
of
$
26.35
plus
110%
overhead
and
profit
or
$
55.34
per
hour.
This
amount
was
multiplied
by
the
hours
per
year
in
Column
E.

bAssume
operation
365
days
per
year
as
specified
in
the
NESHAP
review
document.

cTotal
number
of
affected
process
units
21
facilities
G­
25
TABLE
G.
11:
NEW
SOURCE
ANNUAL
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
OF
THE
HON
Burden
Item
Average
Hours
per
Activity
(
a)
Number
of
Activities
per
year
per
respondent
(
b)
Technical
Hours
per
year
per
respondent
(
c)
Estimated.

Number
New
respondents
(
d)
Estimated
Technical
Hours
per
year
(
e)
Estimated
Managerial
Hours
per
year
(
f)
Estimated
Clerical
Hours
per
year
(
g)
Annual
Cost
in
$
Thousands
per
year
(
h)

1)
Read
Rule
and
Instructions
2.7
93
250
5
1,250
63
125
78
2)
Plan
Activities
3.8
93
355
5
1,775
89
178
110
3)
Training
3.5
38
132
5
660
33
66
41
4)
Create,
Test,

Research
and
Development
2.4
1,778
4,266
5
21,330
1,067
2,133
1,324
5)
Gather
Information,

Monitor/
Inspect
1.4
2,102
2,943
5
14,715
736
1,472
914
6)
Process/
Compile
and
Review
0.8
50
40
5
200
10
20
12
7)
Complete
Reports
11.4
49
557
5
2,785
139
279
173
Total
Annual
Responses
(
Block
13b)
245
8)
Record/
Disclose
10.0
49
489
5
2,445
122
245
152
9)
Store/
File
5.2
51
264
5
1,320
66
132
82
TOTAL
BURDEN
AND
COST
46,480
2,325
4,650
2,886
See
Attachment
I
for
assumptions
and
further
description
of
activities.
G­
26
TABLE
G.
12:
EXISTING
SOURCE
ANNUAL
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
OF
THE
HON
PROVISIONS
Burden
Item
Average
Hours
per
Activity
(
a)
Number
of
Activities
per
year
per
respondent
(
b)
Total
Technical
Hours
per
year
per
respondent
(
c)
Technical
Hours
per
year
per
respondent
for
wastewater
Estimated
Technical
Hours
per
year
(
e)
Estimated
Managerial
Hours
per
year
(
f)
Estimated
Clerical
Hours
per
year
(
g)
Annual
Cost
in
$
Thousands
per
year
(
h)

1)
Read
Rule
and
Instructions
3.6
23
69
14
17,680
884
1,768
$
1,098
2)
Plan
Activities
6.1
13
61
18
16,080
804
1,608
$
998
3)
Training
5.3
4
17
4
4,400
220
440
$
273
4)
Create,
Test,

Research
and
Development
17.8
99
1617
150
400,080
20,004
40,008
$
24,836
5)
Gather
Information,

Monitor/
Inspect
2.5
677
1693
0
406,320
20,316
40,632
$
25,224
6)
Process/
Compile
and
Review
20.0
1
20
0
4,800
240
480
$
298
7)
Complete
Reports
81.2
5
388
18
94,560
4,728
9,456
$
5,870
Total
Annual
Responses
(
Block
13b)
1200
$
0
8)
Record/
Disclose
17.5
26
442
12
107,040
5,352
10,704
$
6,645
9)
Store/
File
6.8
35
222
15
54,480
2,724
5,448
$
3,382
TOTAL
BURDEN
AND
COST
1,105,440
55,272
110,544
$
68,624
See
Attachment
I
for
assumptions
and
further
description
of
activities.
H­
1
Attachment
H
Assumptions
and
Item
Descriptions
for
Attachment
F:
Table
F.
11
(
A)
That
EPA
personnel
would
attend
10%
of
the
performance
tests.
Performance
tests
are
required
only
for
new
sources
in
the
first
3
years
after
promulgation.
It
is
assumed
there
will
be
5
new
sources
per
year
each
with
eight
control
devices.
This
would
mean
the
equivalent
of
40
tests
(
5
x
8)
to
be
performed.
It
is
important
to
note,
however,
that
EPA
attendance
is
dependent
upon
EPA
available
resources,
and
not
the
number
of
tests.

(
B)
That
20%
of
the
initial
tests
must
be
repeated
due
to
failure
of
initial
test.

(
C)
That
all
existing
and
new
sources
must
submit
an
initial
report
within
120
days
of
promulgation
and
an
implementation
plan
or
permit
application
within
12
or
18
months
of
the
compliance
date.
It
is
assumed
that
initial
reports
and
implementation
plans
have
been
submitted
for
existing
sources
and
these
reports
are
only
required
for
new
sources.
The
new
sources
are
most
likely
to
be
collocated
within
existing
plants
and
be
included
in
those
existing
source
reports.

(
D)
That
semiannual
reports
of
results
from
equipment
leak
detection
and
repair
programs
are
required
by
the
equipment
leak
standard.
Sources
are
required
to
comply
with
the
equipment
leak
standard
by
6
months
after
promulgation.
It
is
assumed
that
an
average
of
320
facilities
will
submit
reports
semiannual
(
320
x
2
=
640)
(
even
those
that
use
the
CAR
will
still
have
to
submit
reports
under
the
HON
for
wastewater).

(
E)
that
travel
expenses
equal:

(
2
people/
trip)(
17
trips)($
400
travel/
trip+$
50
per
diem/
trip)

Item
Descriptions:

(
a)
Average
Hours
per
Activity
are
estimates
of
the
specific
activities
and
are
the
basis
for
estimating
the
overall
burden.

(
b)
Number
of
Activities
per
year
represents
the
number
of
reports
expected
to
be
reviewed
and
other
related
activities
during
the
course
of
the
year.
Under
the
performance
test
headings,
these
numbers
are
based
upon
assumptions
(
A)
and
(
B),
above.
For
onetime
reports,
the
total
number
of
reports
expected
over
the
three­
year
period
was
divided
by
three
to
get
an
annual
average
incorporating
assumption
(
C),
above.

(
c)
Estimated
Technical
Hours
per
year
is
the
product
of
(
a)
and
(
b).

(
d)
Estimated
Managerial
Hours
per
year
is
5%
of
(
c).

(
e)
Estimated
Clerical
Hours
per
year
is
10%
of
(
c).

(
f)
Estimated
Annual
Cost
in
$
Thousands
per
year
is
the
total
cost
of
technical,
managerial
and
clerical
hours
and
overhead
using
EPA
FY
1999
labor
rates
using
this
formula:

(
Ht
x
$
40/
hour)+(
Hm
x
$
66/
hour)+(
Hc
x
$
23/
hour)
=
(
f)

$
1,000
H­
2
Where:
Ht
is
(
c),
or
technical
hours
Hm
is
(
d),
or
managerial
hours,
and
Hc
is
(
e),
clerical
hours
PERFORMANCE
TESTS:

1)
Initial
represents
the
activities
during
EPA
attendance
at
an
initial
performance
test.

2)
Repeat
represents
the
same
activities
as
1)
Initial,
except
for
a
repeat
performance
test.

REPORTS
REVIEW:

1)
Initial
represents
the
EPA
review
of
all
initial
reports
received.

2)
Implementation
Plan
or
Permit
Applications
represents
the
EPA
review
of
all
implementation
plans,
or
permit
applications
if
submitted
in
lieu
of
an
implementation
plan.

3)
Compliance
Status
represents
compliance
status
verification
by
the
EPA
for
the
portions
of
the
standard
which
a
source
must
comply
with
before
the
compliance
date
(
see
assumption
(
D)
above).

4)
Review
equipment
leak
monitoring
represents
the
review
and
screening
of
periodic
reports
received
as
a
result
of
the
equipment
leaks
standard.

5)
Notification
of
construction/
reconstruction
represents
the
EPA
review
of
this
notification
from
new
sources.

6)
Notification
of
anticipated
startup
represents
the
EPA
review
of
this
notification
from
new
sources.

7)
Notification
of
actual
startup
represents
the
EPA
review
of
this
notification
from
new
sources.

8)
Notification
of
performance
test
represents
the
EPA
review
of
this
notification
from
new
sources.

9)
Review
of
test
results
represents
the
EPA
review
of
performance
test
results
for
new
sources.

10)
Review
periodic
reports
represents
the
EPA
review
of
periodic
reports.

TOTAL
BURDEN
AND
COST
is
the
sum
of
each
of
the
columns
(
c),
(
d),
(
e)
and
(
f).

Source:
EPA
Labor
Rates
(
Fiscal
Year
1999)

Technical:
25.21
(
GS­
12,
step
5)

Managerial:
41.66
(
GS­
15,
step
5)

Clerical:
14.21
(
GS­
7,
step
5)

Plus
60
percent
for
overhead
and
benefits
I­
1
Attachment
I
Assumptions
and
Item
Descriptions
for
Attachment
G:
Tables
G.
11
and
G.
12
Assumptions
are:

(
A)
That
there
are
240
existing
facilities
out
of
320
that
will
continue
to
comply
with
the
HON,
rather
than
the
CAR.
The
80
facilities
complying
with
the
CAR
will
still
be
required
to
comply
with
the
HON
wastewater
provisions,
as
the
CAR
does
not
include
wastewater
provisions.
The
total
number
of
facilities
will
increase
by
5
new
facilities
per
year.
Since
new
facilities
must
be
in
compliance
at
startup,
the
general
periodic
recordkeeping
and
reporting
burdens
are
included,
which
accounts
for
the
difference
in
the
technical
hours
per
facility.
No
new
facilities
are
expected
to
comply
directly
with
the
CAR.

(
B)
That
the
average
representative
source,
new
and
existing,
will
consist
of
the
following
points
of
burden:

20
parameters
to
monitor
at
control
devices
throughout
the
facility
10
affected
storage
tanks
of
various
capacities
3
affected
major
wastewater
streams
4
affected
transfer
rack
operations
3
overall
leak
detection
and
repair
programs
for
2,000
points
1
emissions
averaging
program
that
involves
10
emission
points
1
facility
wide
inventory
of
emission
points,
Group
1
and
Group
2
8
Process
vents
per
facility
(
C)
That
there
are
5%
(.
05)
managerial
and
10%
(.
10)
clerical
hours
required
for
every
technical
hour.

(
D)
That
some
activities
necessary
to
generate
reports
involve
creating
records
in
the
process,
and
that
these
activities
are
assumed
to
be
reports
activities
alone,
to
avoid
double
counting
these
as
records
activities
as
well.
Therefore,
only
items
8
and
9
are
considered
records
burdens
directly.

Item
Descriptions:

(
a)
Average
Hours
per
Activity
is
back­
calculated
by
dividing
(
b)
into
(
c).
Since
the
activities
within
each
burden
category
can
vary
significantly,
it
is
too
inaccurate
to
assume
an
average
to
use
to
calculate
(
c).
Estimated
activity
technical
hours
are
summarized
to
obtain
(
c)
first,
then
back
calculate
for
(
a)
with
an
estimated
(
b).

(
b)
Estimated
Number
of
Activities
per
year
per
source
represents
the
assumed
typical
number
of
separate
activities
a
source
may
encounter
during
one
year.
This
number
may
vary
from
facility
to
facility
depending
on
consolidation
of
activities,
collocated
readings,
etc.
Since
so
much
variability
exists,
it
is
important
to
note
that
this
is
an
estimate.
This
number
was
only
used
to
backcalculate
(
a).

(
c)
Technical
Hours
per
year
per
source
is
the
actual
best
estimate
of
the
burden
for
each
burden
item.
The
three­
year
separate
I­
2
activity
burdens
were
divided
by
three,
where
appropriate,
and
then
summarized
to
include
in
this
column.
The
technical
hours
for
new
sources
is
higher
because
some
periodic
compliance
reports
and
records
are
required
at
startup.
Existing
sources
do
not
encounter
these
reports
and
record
burdens
for
three
years
after
promulgation.

(
d)
(
Table
G.
11)
Estimated
Number
of
New
Sources
reflect
the
number
given
in
assumption
(
A),
above.
(
Table
G.
12)

Technical
Hours
Per
Year
Per
Source
for
Wastewater
are
the
annual
technical
hours
associated
with
recordkeeping
and
reporting
to
ensure
compliance
with
requirements
for
wastewater.
As
discussed
in
assumption
(
A),
facilities
complying
with
the
CAR
will
comply
with
the
HON
wastewater
requirements.
Burden
hours
per
source,
per
emission
type
are
shown
in
Table
B.
1.

(
e)
Estimated
Technical
Hours
per
year
is
the
product
of
(
c)
and
(
d)
for
new
facilities
(
Table
G.
11).
For
Table
G.
12,
estimated
technical
hours
are
the
product
of
(
c)
and
the
number
of
existing
facilities
complying
with
all
of
the
HON
(
240)
added
to
the
product
of
(
d)
and
the
number
of
facilities
complying
with
only
the
wastewater
provisions
(
80).

(
f)
Estimated
Managerial
Hours
per
year
is
5%
of
(
e).

(
g)
Estimated
Clerical
Hours
per
year
is
10%
of
(
e).

(
h)
Estimated
Annual
Cost
in
$
Thousands
per
year
is
the
total
cost
of
technical,
managerial
and
clerical
hours
and
overhead
using
1999
Bureau
of
Labor
Statistics
and
a
110%
increase
for
overhead
and
profit:

(
Ht
x
$
54.94/
hour)+(
Hm
x
$
73.93/
hour)+(
Hc
x
$
34.42/
hour)
=
(
h)

1,000
Where:
Ht
is
(
e),
or
technical
hours
Hm
is
(
f),
or
managerial
hours,
and
Hc
is
(
g),
clerical
hours
1)
Read
Rule
and
Instructions
are
the
activities,
less
training,
which
involve
comprehending
the
provisions
in
the
standard
and
understanding
how
they
apply
to
the
respective
points
at
a
facility.

2)
Plan
Activities
represents
such
burdens
as
design,
redesign,
scheduling
as
well
as
drafting
the
implementation
plan,
and
selecting
methods
of
compliance.

3)
Training
represents
the
portion
(
assumed
40%)
of
activities
from
1)
Read
Rule
and
Instruction
for
which
an
average
facility
would
elect
to
provide
class
room
instruction.
The
standard
does
not
require
specific
training
itself.

4)
Create,
Test,
Research
and
Development
are
the
activities
involving
testing,
retesting,
establishing
operating
range
for
parameters
and
analyzing
point
by
point
applicability.
Monitor
related
refit,
calibration
and
maintenance
activities
are
also
included
under
this
heading.

5)
Gather
Information,
Monitor
and
Inspect
are
the
activities
involving
physical
inspections
of
equipment,
collection
of
monitored
data
and
other
related
activities.

6)
Process/
Compile
and
Review
are
the
activities
that
involve
analysis
of
the
information
collected
for
accuracy,
compliance
I­
3
and
appropriate
reports
and
records
required
as
a
result.

7)
Complete
Reports
represents
the
activities
normally
associated
with
filling
out
forms.
Since
the
standard
requires
no
standard
forms,
these
activities
relate
to
the
preparing
of
formal
reports
and
cover
letters
as
appropriate.

8)
Record/
Disclose
are
activities
which
are
solely
recordkeeping
which
occur
once
the
appropriate
report
information
has
been
extracted
[
see
assumption
(
D)]
above.
These
activities
involve
software
translation,
duplication
or
archival
processes
normally
associated
with
data
management
and
storage
common
to
this
industry.

9)
Store/
File
are
again
activities
which
are
solely
recordkeeping
which
occur
once
the
appropriate
report
information
has
been
extracted
(
see
assumption
(
D)
above).
These
activities
involve
the
management
life
cycle
of
records,
from
the
time
they
are
filed
and
boxed
up,
to
the
time
they
are
disposed.

TOTAL
BURDEN
AND
COST
is
the
sum
of
each
of
the
columns
(
e),
(
f),
(
g)
and
(
h).
J­
1
Attachment
J1
ANNUAL
COST
BURDEN
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
AS
A
RESULT
OF
SUBPART
VV,
THE
HON,
AND
THE
CAR
Subpart
Number
of
Entities
Complying
with
Subparta
(
B)
Number
of
Entities
Using
Contractor
for
leak
detection
and
repair
(
LDAR)

(
C)
Number
of
Component
s
per
Entityc
(
D)
Cost
per
Entityd
(
E)
Total
Annual
Coste
(
F)

VV
95
76
10,000
50,000.00
$
3,800,000
HON
­
existing
sources
240
192
2,000
$
10,000
$
1,920,000f
HON
­

New
Sources
5
4
2,000
$
10,000
$
40,000f
CAR
80
64
2,600
$
13,000
$
832,000
Total
$
6,592,000
aMultiple
sources
are
located
at
individual
facilities.
The
costs
presented
are
estimated
on
a
facility
or
entity
basis.

bEstimate
that
80
percent
of
entities
will
contract
out
LDAR
services.
C
=
0.8
x
B
cFor
Subpart
VV
and
the
HON,
the
number
of
components
per
facility
is
taken
from
the
supporting
statement
for
the
most
recent
ICR.
The
number
of
components
at
a
HON
entity
is
multiplied
by
the
ratio
of
CAR
sources
per
entity
to
HON
sources
per
entity
to
estimate
the
number
of
components
at
a
CAR
entity.
It
is
anticipated
that
the
entities
opting
to
comply
with
the
CAR
will
comprise
HON
facilities
and
additional,
co­
located
individual
sources.

dE
=
D
x
$
5.00.
In
the
supporting
statements
for
the
most
recent
ICRs
for
Subpart
VV
and
the
HON,
it
is
estimated
that
contracting
out
LDAR
costs
$
5.00
per
component.

eF
=
E
x
C
fFrom
Attachment
J2
J­
2
Attachment
J2:
Annual
Labor
Costs
for
Contracting
LDAR
Program
(
Subpart
H
and
I)

Existing
Sources:
$
10,000a
*
192b
=
$
1,920,000c
New
Sources:
$
10,000
*
4
=
$
40,000
Total
Annual
Recurring
Cost
Burden:
=
$
1,960,000
a
Estimate
an
average
cost
of
$
5.00/
component
to
perform
LDAR
and
estimate
2,000
components
at
an
entity.
b
Existing
sources:
240
(
0.8)
will
contract
out
LDAR;
New
sources:
5*
(
0.8)
will
contract
out
LDAR
c
A
x
C
=
D
J­
3
Attachment
J3:
Summary
of
Capital/
Startup
and
Operation
and
Maintenance
Costs
for
the
CAR
and
the
Referencing
Subparts
NSPS
Subpart
Ka
a.
Total
Capital/
Startup
Cost
of
Control
and
Monitoring
Equipment:
The
total
Capital/
Start­
up
costs
for
this
ICR
are
$
0.

b.
Total
Cost
of
Operation
and
Maintenance
of
Control
and
Monitoring
Equipment:
The
total
Operating
and
Maintenance
(
O&
M)
Costs
for
this
ICR
is
$
0.

c.
Total
Capital/
Startup
and
O&
M
Cost:
The
total
Capital
and
O&
M
Costs
are
$
0.

NSPS
Subpart
Kb
a.
Total
Capital/
Startup
Cost
of
Control
and
Monitoring
Equipment:
The
total
Capital/
Start­
up
costs
for
this
ICR
are
$
1,010,666.
This
is
the
cost
for
111
new
storage
vessels.

b.
Total
Cost
of
Operation
and
Maintenance
of
Control
and
Monitoring
Equipment:
The
total
Operating
and
Maintenance
(
O&
M)
Costs
for
this
ICR
is
$
3,704,024.

c.
Total
Capital/
Startup
and
O&
M
Cost:
The
total
Capital
and
O&
M
Costs
are
$
4,714,690.

NSPS
Subpart
VV
a.
Total
Capital/
Startup
Cost
of
Control
and
Monitoring
Equipment:
The
capital/
startup
costs
of
this
regulation
are
$
35,000.
This
is
based
on
the
average
cost
of
a
monitor
with
a
5
year
expected
life.
The
equipment
is
not
capitalized,
so
no
discount
rate
applies.
The
average
annual
cost
is
therefore
7000/
5
or
$
1400/
yr.
It
is
also
estimated
that
80%
of
facilities
contract
out
LDAR
services
and
20%
perform
in­
house.
Those
facilities
which
contract
out
will
purchase
one
unit
as
backup;
the
remaining
facilities
performing
LDAR
in­
house
will
purchase
5
units
to
support
the
program.
There
are
currently
1120
affected
sources
located
at
84
facilities
or
an
average
of
13.3
sources
per
facility.
The
total
number
of
units
to
be
purchased
it
therefore
(
13*.
8)
(
1
unit)
+
(
13*.
2)(
5
units)
=
25
units.

b.
Total
Cost
of
Operation
and
Maintenance
of
Control
and
Monitoring
Equipment:
The
operation
of
the
monitors
is
included
in
the
monitoring
costs.
Maintenance
costs
on
these
units
is
incidental,
therefore
no
maintenance
or
operation
costs
incur.

c.
Total
Capital/
Startup
and
O&
M
Cost:
J­
4
The
total
Capital
and
O&
M
Costs
are
$
35,000.

NSPS
Subpart
DDD
a.
Total
Capital/
Startup
cost
of
Control
and
Monitoring
Equipment:
The
capital/
startup
startup
costs
for
this
regulation
are
$
300,000.
This
is
based
on
10
new
sources
per
year
multiplied
by
$
30,000
per
source
for
instrumentation
and
systems,
including
computers
and
software.

b.
Total
Cost
of
Operation
and
Maintenance
of
Control
and
Monitoring
Equipment:
The
annual
operation
and
maintenance
costs
are
$
630,000
dollars.
This
is
based
on
80
existing
sources
plus
10
new
sources
over
the
life
of
the
ICR
multiplied
by
$
7,000
for
upkeep
of
the
monitoring
devices
and
computers.

c.
Total
Capital/
Startup
and
O&
M
Cost:
The
total
Capital
and
O&
M
Costs
are
$
930,000.

NSPS
Subpart
NNN/
III
a.
Total
Capital/
Startup
Cost
of
Control
and
Monitoring
Equipment:
The
start­
up
cost
of
instrumentation
equipment,
which
includes
computers
and
software,
is
approximately
$
13,500
per
new
affected
facility
for
both
Subpart
III,
Air
Oxidation
Operations
and
Subpart
NNN,
Distillation
Operations
or
a
total
of
$
2,403,000
(
total
of
178
new
sources
x
$
13,500/
source).

b.
Total
Cost
of
Operation
and
Maintenance
of
Control
and
Monitoring
Equipment:
The
cost
to
industry
associated
the
operation
and
periodic
maintenance.
The
average
annualized
burden
is
estimated
to
be
$
1,350
per
year
per
affected
facility
($
13,500
discounted
over
10
years
by
straight
line
depreciation
method)
for
Subpart
III
and
for
Subpart
NNN
for
a
total
of
$
1,830,600
[($
1350
x
1356)
total
number
of
new
and
existing
affected
sources
under
NNN
and
III].
These
estimates
were
obtained
from
consultation
with
industry
representatives.

c.
Total
Capital/
Startup
and
O&
M
Cost:
The
total
Capital
and
O&
M
Costs
are
$
4,233,600.

NSPS
Subpart
RRR
a.
Total
Capital/
Startup
cost
of
Control
and
Monitoring
Equipment:
The
capital/
startup
startup
costs
for
this
regulation
are
$
500,000
dollars
per
year.
This
is
based
on
20
new
sources
per
year
multiplied
by
$
25,000
for
computer
and
software
discounted
over
10
years
at
7%.
These
estimates
were
obtained
from
consultation
with
industry
representatives.

b.
Total
Cost
of
Operation
and
Maintenance
of
Control
and
Monitoring
Equipment:
J­
5
The
annual
operation
and
maintenance
costs
are
$
77,500
dollars.
This
is
based
on
155
existing
sources
multiplied
by
$
500
for
upkeep
of
the
monitoring
device.

c.
Total
Capital/
Startup
and
O&
M
Cost:
The
total
Capital
and
O&
M
Costs
are
$
577,500.

NESHAP
Subpart
BB
a.
Total
Capital/
Startup
cost
of
Control
and
Monitoring
Equipment:
Startup
cost
were
identified
in
previous
ICR.

b.
Total
Cost
of
Operation
and
Maintenance
of
Control
and
Monitoring
Equipment:
There
are
no
O&
M
cost
associated
because
no
CEMs
are
employed.

c.
Total
Capital/
Startup
and
O&
M
Cost:
The
total
Capital
and
O&
M
Costs
are
$
0.

NESHAP
Subpart
Y
a.
Total
Capital/
Startup
Cost
of
Control
and
Monitoring
Equipment:
The
only
type
of
industry
costs
associated
with
the
information
collection
activity
in
the
standards
is
labor
cost.
There
are
no
capital/
startup
costs.

b.
Total
Cost
of
Operation
and
Maintenance
of
Control
and
Monitoring
Equipment:
There
are
no
operation
and
maintenance
costs.

c.
Total
Capital/
Startup
and
O&
M
Cost:
The
total
Capital
and
O&
M
Costs
are
$
0.

NESHAP
Subpart
V
a.
Total
Capital/
Startup
Cost
of
Control
and
Monitoring
Equipment:
Startup
cost
were
identified
in
previous
ICR.

b.
Total
Cost
of
Operation
and
Maintenance
of
Control
and
Monitoring
Equipment:
There
are
no
O&
M
cost
associated
because
no
CEMs
are
employed.

c.
Total
Capital
and
O&
M
Cost
The
total
Capital
and
O&
M
Costs
are
$
0.

NESHAP
HON:
J­
6
Subpart
G
a.
Total
Capital/
Startup
Cost
of
Control
and
Monitoring
Equipment:
Estimate
the
cost
to
purchase
monitoring
equipment
and
computer
equipment
and
software
is
approximately
$
20­
30K
for
process
vents
and
wastewater
operations,
or
an
average
of
$
25K
with
a
10­
year
life
expectancy
and
a
7%
depreciation
rate,
or
$
2225
per
year.
There
are
no
associated
costs
for
transfer
racks
and
storage
tanks.
Only
new
sources
need
to
buy
control
and
monitoring
equipment;
therefore,
the
total
capital/
startup
cost
is
$
25,000
x
5
or
$
11,125.

b.
Total
Cost
of
Operation
and
Maintenance
of
Control
and
Monitoring
Equipment:
The
cost
to
industry
associated
with
the
operation
and
maintenance
(
O&
M)
is
approximately
$
100­
500K
per
year
(
capital/
startup
depreciation
not
included)
for
reactor
process
vents
and
wastewater
operations.
The
cost
associated
with
the
operation
and
maintenance
$
50­
100K
per
year
(
capital/
startup
depreciation
not
included)
for
distillation
units
process
vents.
There
are
no
associated
costs
for
transfer
racks
and
storage
tanks.
The
average
O&
M
cost
is
assumed
to
be
the
average
of
the
two
ranges,
or
$
275,000
per
year.
Operation
and
maintenance
incur
for
both
new
and
existing
sources.
The
total
O&
M
is
therefore
$
275,000
x
245
or
$
67,375,000.

Subpart
H
a.
Total
Capital/
Startup
Cost
of
Control
and
Monitoring
Equipment:
Only
new
sources
will
buy
an
organic
volatile
analyzer.
Estimate
the
average
cost
of
a
monitor
is
$
7,000
with
a
5
year
expected
life.
The
equipment
is
not
capitalized,
so
no
discount
rate
applies.
The
average
annual
cost
is
therefore
7000/
5
or
$
1400/
yr.
Estimate
that
80%
of
facilities
contract
out
LDAR
services
and
20%
perform
in­
house.
Those
facilities
which
contract
out
(
4
facilities)
will
purchase
one
unit
as
backup;
the
remaining
facilities
performing
LDAR
in­
house
(
1
facility)
will
purchase
5
units
to
support
the
program.
The
total
annual
capital/
startup
cost
is
therefore
9
units
x
1400/
unit
or
$
12,600/
yr.

b.
Total
Cost
of
Operation
and
Maintenance
of
Control
and
Monitoring
Equipment:
The
operation
of
the
monitors
is
included
in
the
monitoring
costs.
Maintenance
costs
on
these
units
is
incidental,
therefore,
no
maintenance
or
operation
costs
incur.

c.
Total
Capital
and
O&
M
Cost
for
Subparts
F,
G,
H,
and
I:
The
total
Capital
and
O&
M
Costs
are
$
67,399,000.

Part
65
CAR
a.
Total
Capital/
Startup
Cost
of
Control
and
Monitoring
Equipment:
J­
7
Under
the
CAR,
it
is
assumed
all
new
sources
start
out
under
the
referencing
subpart.
Therefore,
there
is
no
capital/
startup
cost
associated
with
this
subpart.

b.
Total
Cost
of
Operation
and
Maintenance
of
Control
and
Monitoring
Equipment:
The
HON
is
the
basis
for
determining
O&
M
costs
for
the
CAR.
The
average
cost
per
source,
based
on
the
HON
is
$
275,000
per
year
for
a
total
of
$
22,000,000.

c.
Total
Capital/
Startup
and
O&
M
Cost:
The
total
Capital
and
O&
M
Costs
are
$
22,000,000.
