1
SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
NSPS
for
VOC
Emissions
From
Petroleum
Refinery
Wastewater
Systems
(
40
CFR
part
60,
subpart
QQQ)
(
Renewal)

1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
NSPS
for
VOC
Emissions
From
Petroleum
Refinery
Wastewater
Systems
(
40
CFR
part
60,
subpart
QQQ)
(
Renewal)

1(
b)
Short
Characterization/
Abstract
The
New
Source
Performance
Standards
(
NSPS)
for
petroleum
refinery
wastewater
systems
for
the
regulations
published
at
40
CFR
60.690
were
proposed
on
May
4,
1987
and
promulgated
on
November
23,
1988.
These
standards
apply
to
the
following
affected
facilities
in
petroleum
refinery
wastewater
systems:
individual
drain
systems,
oil­
water
separators,
and
aggregate
facilities
commencing
construction,
modification
or
reconstruction
after
the
date
of
proposal.
An
individual
drain
system
consists
of
all
process
drains
connected
to
the
first
downstream
junction
box.
An
oil­
water
separator
is
the
wastewater
treatment
equipment
used
to
separate
oil
from
water.
An
aggregate
facility
is
an
individual
drain
system
together
with
ancillary
downstream
sewer
lines
and
oil­
water
separators,
down
to
and
including
the
secondary
oil­
water
separator,
as
applicable.
Aggregate
facilities
are
intended
to
capture
any
potential
volatile
organic
compound
(
VOC)
emissions
within
the
petroleum
refinery
wastewater
system
during
expansions
of
and
additions
to
the
system.
There
are
no
additional
recordkeeping
or
reporting
requirements
for
aggregate
facilities.
For
the
purposes
of
this
document,
new
facilities
are
those
affected
facilities
that
have
had
construction,
modification
or
reconstruction
within
the
last
three
years.
This
information
is
being
collected
to
determine
compliance
with
40
CFR
part
60,
subpart
QQQ.

In
general,
all
NSPS
standards
require
initial
notifications,
performance
tests,
and
periodic
reports.
Owners
or
operators
are
also
required
to
maintain
records
of
the
occurrence
and
duration
of
any
startup,
shutdown,
or
malfunction
in
the
operation
of
an
affected
facility,
or
any
period
during
which
the
monitoring
system
is
inoperative.
These
notifications,
reports,
and
records
are
essential
in
determining
compliance,
and
are
required
of
all
sources
subject
to
NSPS.

For
most
of
the
recordkeeping
requirements
for
this
rule
any
owner
or
operator
subject
to
the
provisions
of
this
part
shall
maintain
a
file
of
these
measurements
and
retain
the
file
for
at
least
two
years
following
the
date
of
such
measurements,
maintenance
reports,
and
records.
However,
some
records
are
required
to
be
kept
for
ten
years
and
other
records
are
required
to
be
kept
for
the
life
of
the
source,
or
the
life
of
the
facility.
All
reports
are
sent
to
the
delegated
state
or
local
authority.
In
the
event
that
there
is
no
such
delegated
authority,
the
reports
are
sent
directly
to
2
the
United
States
Environmental
Protection
Agency
(
EPA)
regional
office.
Once
received
by
the
authority,
reports
are
reviewed
and
the
data
is
entered,
analyzed,
and
maintained
in
the
Air
Facility
System
(
AFS).
Information
from
these
reports
can
be
used
by
any
regions,
states,
agencies
and
offices
with
access
to
AFS
and
may
be
used
in
determining
where
inspections
and
enforcement
actions
may
be
necessary.

Approximately
135
sources
are
currently
subject
to
the
regulation,
and
it
is
estimated
that
no
additional
sources
will
become
subject
to
the
regulation
in
the
next
three
years.
It
is
further
assumed
that
there
is
an
average
of
two
affected
facilities
per
plant.
The
annual
cost
of
this
ICR
will
be
$
17,550
dollars
for
non­
labor
and
$
589,385
dollars
for
labor
(
based
on
a
labor
burden
of
9,237
hours)
for
a
total
of
$
606,935
dollars.

These
estimates
are
based
on
industry
journals
and
industry
consultation.
The
number
of
refineries
has
declined
since
the
previous
approval
due
to
consolidation
and
closures,
but
is
not
expected
to
decline
further
in
the
next
three
years.
The
active
(
previous)
ICR
speculated
that
the
number
of
refineries
would
remain
constant
over
the
following
three
years;
this
estimate
appears
to
have
been
incorrect.

The
active
(
previous)
ICR
had
the
following
Terms
of
Clearance:

"
This
Information
Collection
Request
is
approved
for
three
years.
When
EPA
resubmits
the
ICR
for
renewal,
the
Agency
should
update
the
wage
rates
and
verify
that
the
rates
have
been
properly
loaded
to
include
overhead,
consistent
with
current
EPA
and
OMB
guidelines."

EPA
has
addressed
each
item
of
concern
in
the
Terms
of
Clearance
by
updating
the
industry
and
Agency
wage
rates,
based
on
recent
information
provided
by
the
Department
of
Labor
(
DOL)
and
the
Office
of
Personnel
Management
(
OPM).
These
rates
have
been
loaded
to
account
for
overhead.
The
updated
wage
and
overhead
rates
for
industry
are
included
in
Section
6(
b)(
i)
of
this
document.
The
updated
wage
and
overhead
rates
for
the
Agency
are
included
in
Section
6(
c)
of
this
document.

2.
Need
for
and
Use
of
the
Collection
2(
a)
Need/
Authority
for
the
Collection
The
EPA
is
charged
under
Section
111
of
the
Clean
Air
Act
(
CAA),
as
amended,
to
establish
standards
of
performance
for
new
stationary
sources
that
reflect:

.
.
.
application
of
the
best
technological
system
of
continuous
3
emissions
reduction
which
(
taking
into
consideration
the
cost
of
achieving
such
emissions
reduction,
or
any
non­
air
quality
health
and
environmental
impact
and
energy
requirements)
the
Administrator
determines
has
been
adequately
demonstrated.
Section
111(
a)(
l).

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

In
the
Administrator's
judgment,
VOC
emissions
from
petroleum
refinery
wastewater
systems
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
the
NSPS
were
promulgated
for
this
source
category
at
40
CFR
part
60,
subpart
QQQ.

2(
b)
Practical
Utility/
Users
of
the
Data
The
control
of
emissions
of
VOC
from
petroleum
refinery
wastewater
systems
requires
not
only
the
installation
of
properly
designed
equipment,
but
also
the
operation
and
maintenance
of
that
equipment.
Emissions
of
VOC
from
petroleum
refinery
wastewater
systems
are
the
result
of
operation
of
the
affected
facilities.
The
subject
standards
are
achieved
by
the
capture
or
reduction
of
VOC
emissions
using
incinerators,
flares
and
carbon
adsorbers,
and
by
leak
detection
and
repair
procedures.
The
notifications
required
in
the
applicable
regulations
are
used
to
inform
the
Agency
or
delegated
authority
when
a
source
becomes
subject
to
the
requirements
of
the
regulations.
The
reviewing
authority
may
then
inspect
the
source
to
check
if
the
pollution
control
devices
are
properly
installed
and
operated,
leaks
are
being
detected
and
repaired,
and
the
regulations
are
being
met.
Performance
test
reports
are
needed
as
these
are
the
Agency's
record
of
a
source's
initial
capability
to
comply
with
the
emission
standards,
and
serve
as
a
record
of
the
operating
conditions
under
which
compliance
was
achieved.
The
required
operating
conditions
for
enclosed
combustion
devices
are
a
VOC
destruction
efficiency
of
95
percent
or
greater,
and/
or
a
minimum
residence
time
of
0.75
seconds
at
a
minimum
temperature
of
1,500
degrees
Fahrenheit
(

F).
The
required
operating
condition
for
vapor
recovery
systems
(
e.
g.,
carbon
adsorbers)
is
a
VOC
recovery
efficiency
of
95
percent
or
greater.
The
required
operating
conditions
for
flares
are
no
visible
emissions
and
flame
must
be
present
at
all
times.
The
required
operating
condition
for
closed
vent
systems
is
for
emissions
to
be
non­
detectable,
as
indicated
by
an
instrument
reading
of
less
than
500
parts
per
million
VOC
above
backgound.
The
semiannual
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.
The
information
generated
by
the
monitoring,
recordkeeping
and
reporting
requirements
described
in
this
ICR
is
used
by
the
Agency
to
ensure
that
facilities
affected
by
the
NSPS
continue
to
operate
the
control
equipment
in
compliance
with
the
regulation.
Adequate
monitoring,
recordkeeping,
and
reporting
are
necessary
to
ensure
compliance
with
the
applicable
regulations,
as
required
by
the
Clean
Air
Act.
The
information
1
Worldwide
Refineries­
Capacities
as
of
January
1,
2003.
Oil
&
Gas
Journal.
Penn
Well
Publishing
Company,
December
23,
2002.

4
collected
from
recordkeeping
and
reporting
requirements
is
also
used
for
targeting
inspections,
and
is
of
sufficient
quality
to
be
used
as
evidence
in
court.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
The
requested
recordkeeping
and
reporting
are
required
under
40
CFR
part
60,
subpart
QQQ.

3(
a)
Nonduplication
If
the
subject
standards
have
not
been
delegated,
the
information
is
sent
directly
to
the
appropriate
EPA
regional
office.
Otherwise,
the
information
is
sent
directly
to
the
delegated
state
or
local
agency.
If
a
state
or
local
agency
has
adopted
its
own
similar
standards
to
implement
the
federal
standards,
a
copy
of
the
report
submitted
to
the
state
or
local
agency
can
be
sent
to
the
Administrator
in
lieu
of
the
report
required
by
the
federal
standards.
Therefore,
no
duplication
exists.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
An
announcement
of
a
public
comment
period
for
the
renewal
of
this
ICR
was
published
in
the
Federal
Register
(
68
FR
62289)
on
November
3,
2003.
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.

3(
c)
Consultations
Published
industry
data,
an
industry
trade
association
and
the
EPA
database
OTIS
were
used
for
this
ICR.
A
dataset
from
the
Penn
Well
Publishing
Company
(
publishers
of
Oil
&
Gas
Journal)
was
the
primary
source
of
information
regarding
the
number
of
existing
affected
sources1.
Also,
EPA
consulted
with
Norbert
Dee
and
Tom
Wigglesworth
of
the
National
Petroleum
Refiners
Association
(
NPRA)
at
(
202)
457­
0480.
They
provided
information
regarding
the
number
of
refineries,
industry
growth
rate,
level
of
electronic
reporting,
and
representation
of
small
businesses,
as
well
as
anecdotal
information
regarding
industry's
opinion
of
the
rule.
According
to
the
NPRA,
respondents
perceive
the
record
keeping
and
reporting
burden
as
"
fairly
reasonable."
However,
the
prevailing
opinion
is
that
the
language
of
the
rule
could
be
clarified.
There
is
some
confusion
over
the
definitions
of
the
terms
"
individual
drain
system,"
"
aggregate
facility,"
and
"
stormwater
sewer
system."
Respondents
believe
that
the
definition
of
"
oily
wastewater"
should
be
revised
to
include
a
minimum
threshold;
the
NPRA
suggested
a
threshold
concentration
of
500
parts
per
million
of
organics.
Also,
there
is
some
confusion
over
the
applicability
of
the
rule.
For
example,
some
respondents
are
unclear
as
to
5
whether
the
rule
would
apply
to
a
source
that
installs
new
piping
as
part
of
a
sewer
system.

3(
d)
Effects
of
Less
Frequent
Collection
Less
frequent
information
collection
would
decrease
the
margin
of
assurance
that
facilities
are
continuing
to
meet
the
standards.
Requirements
for
information
gathering
and
recordkeeping
are
useful
techniques
to
ensure
that
good
operation
and
maintenance
practices
are
applied
and
emission
limitations
are
met.
If
the
information
required
by
these
standards
was
collected
less
frequently,
the
likelihood
of
detecting
poor
operation
and
maintenance
of
control
equipment
and
noncompliance
would
decrease.

3(
e)
General
Guidelines
None
of
these
reporting
or
recordkeeping
requirements
violate
any
of
the
regulations
established
by
OMB
at
5
CFR
1320.5.

Some
records
must
be
kept
for
the
life
of
the
source,
or
the
life
of
the
facility,
as
required
by:
40
CFR
60.697(
h)
(
stormwater
sewer
systems
exclusion),
40
CFR
60.697(
i)
(
ancillary
equipment
exclusion),
and
40
CFR
60.697(
j)
(
non­
contact
cooling
water
systems
exclusion)

Other
records
must
be
kept
for
ten
years,
as
required
by:
40
CFR
60.697(
k)(
1).
This
recordkeeping
requirement
is
for
alternative
standards
for
certain
oilwater
separators.
It
is
not
mandatory,
but
voluntary.

3(
f)
Confidentiality
Any
information
submitted
to
the
Agency
for
which
a
claim
of
confidentiality
is
made
will
be
safeguarded
according
to
the
Agency
policies
set
forth
in
Title
40,
Chapter
1,
part
2,
subpart
B
­
Confidentiality
of
Business
Information
(
see
40
CFR
2;
41
FR
36902,
September
1,
1976;
amended
by
43
FR
40000,
September
8,
1978;
43
FR
42251,
September
20,
1978;
44
FR
17674,
March
23,
1979).

3(
g)
Sensitive
Questions
None
of
the
reporting
or
recordkeeping
requirements
contain
sensitive
questions.

4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
SIC
Codes
6
The
respondents
to
the
recordkeeping
and
reporting
requirements
are
the
owners
or
operators
of
petroleum
refinery
wastewater
systems
that
commenced
construction,
modification,
or
reconstruction
after
May
4,
1987.
The
SIC
code
for
the
respondents
affected
by
the
standards
is
SIC
(
United
States
Standard
Industrial
Classification)
2911,
which
corresponds
to
NAICS
(
North
American
Industry
Classification
System)
324110
for
petroleum
refineries.

The
Agency
assumes
that
all
petroleum
refineries
utilize
individual
drain
systems
and/
or
oil­
water
separators
for
treatment
of
wastewater
on­
site,
and
that
each
refinery
has
constructed,
reconstructed,
or
modified
at
least
one
component
of
the
wastewater
system
since
May
4,
1987.
Therefore,
the
Agency
assumes
that
all
petroleum
refineries
are
respondents
to
the
recordkeeping
and
reporting
requirements.

4(
b)
Information
Requested
(
i)
Data
Items
All
data
in
this
ICR
that
are
recorded
and/
or
reported
are
required
by
40
CFR
part
60,
subpart
QQQ
­
Standards
of
Performance
for
VOC
Emissions
From
Petroleum
Refinery
Wastewater
Systems.

A
source
must
make
the
following
reports:

Notification
Reports
Notification
of
construction
or
reconstruction.
60.7(
a)(
1)

Notification
of
modification.
60.7(
a)(
4)

Notification
of
actual
startup
date.
60.7(
a)(
3)

Notification
of
initial
performance
test.
60.8(
a)

Notification
of
election
to
construct
and
operate
a
completely
closed
drain
system.
60.693­
1(
c)
and
60.698(
a)

Notification
of
election
to
construct
and
operate
a
floating
roof
on
an
oil­
water
separator
tank
or
other
subject
auxiliary
equipment.
60.693­
2(
b)
and
60.698(
a)

Notification
of
intent
to
use
an
alternative
means
of
emission
limitation.
60.694(
c)
Notification
Reports
7
Notification
of
intent
to
use
a
VOC
control
device
other
than
a
carbon
adsorber
to
meet
the
requirements
of
60.692­
5(
a),
with
information
describing
the
control
device
and
the
process
parameters
being
monitored.
60.695(
b)

Demonstration
that
an
alternative
operational
or
process
parameter
will
ensure
that
the
control
device
is
operated
in
compliance
with
standards.
60.695(
c)

Initial
certification
that
the
requirements
for
equipment
and
inspections
have
been
met.
60.698(
b)(
1)

Notification
of
delay
in
compliance
along
with
the
date
of
the
next
scheduled
refinery
or
process
unit
shutdown
and
reasons
why
delay
is
necessary.
60.698(
e)

Reports
Semiannual
reports
of
excess
emissions
from
and
performance
of
continuous
monitoring
systems,
and/
or
summary
report
forms.
60.7(
c)
and
60.7(
d)

Semiannual
certification
that
required
inspections
have
been
carried
out.
60.698(
b)(
1)

Initial
performance
test
data
and
result
for
flares.
60.8(
a)
and
60.698(
b)(
2)

Initial
and
semiannual
inspection
reports
detailing
problems
resulting
in
VOC
emissions
and
the
corrective
actions
taken.
60.698(
c)

Semiannual
reports
on
control
device
performance.
60.698(
d)

A
source
must
keep
the
following
records:

Recordkeeping
Keep
records
of
startups,
shutdowns,
and
malfunctions
of
affected
facilities;
malfunctions
of
control
devices;
and
periods
where
the
continuous
monitoring
system
is
inoperative.
60.7(
b)
Recordkeeping
8
Keep
records
of
measurements,
performance
evaluations,
calibration
checks,
adjustments
and
maintenance
related
to
continuous
monitoring
systems.
60.7(
f)

Keep
records
of
location,
date,
and
corrective
actions
for
process
drains
not
in
compliance.
60.697(
b)(
1)

Keep
records
of
location,
date,
and
corrective
actions
for
junction
boxes
out
of
compliance.
60.697(
b)(
2)

Keep
records
of
location,
date,
and
corrective
actions
for
sewer
lines
out
of
compliance.
60.697(
b)(
3)

Keep
records
of
location,
date,
and
corrective
actions
for
oil­
water
separators
out
of
compliance.
60.697(
c)

Keep
records
of
location,
date,
and
corrective
actions
for
closed
vent
systems
and
completely
closed
drain
systems
out
of
compliance.
60.697(
d)

Keep
records
of
expected
date
of
repairs
if
emission
point
cannot
be
repaired
without
a
process
shutdown;
reason
for
delay;
signature
of
company
official
who
authorizes
the
delay;
and
the
date
of
actual
repairs.
60.697(
e)

Keep
records
of
copy
of
design
specifications
for
all
equipment
used
to
comply
with
the
standards.
60.697(
f)(
1)
and
(
2)

Keep
records
of
information
pertaining
to
the
operation
and
maintenance
of
closed­
drain
systems
and
closed­
vent
systems.
60.697(
f)(
3)

Keep
records
of
location,
plans
or
specifications
for
inactive
process
drains.
60.697(
g)

Keep
records
of
location,
plans
or
specifications
for
exempted
stormwater
sewer
systems.
60.697(
h)

Keep
records
of
location,
plans
or
specifications
for
exempted
ancillary
equipment.
60.697(
i)

Keep
records
of
location,
plans
or
specifications
for
exempted
noncontact
cooling
water
systems.
60.697(
j)
2
Consultation
with
Norbert
Dee
and
Tom
Bigglesworth,
National
Petroleum
Refiners
Association.

9
Electronic
Reporting
The
majority
of
the
record
keeping
requirements
associated
with
this
rule
are
related
to
visual
inspections
of
transport
systems
and
other
facilities.
Personnel
at
the
affected
source
must
perform
these
inspections
and
note
the
nature
of
the
corrective
actions
taken.
Because
of
the
human
labor
involved
with
these
requirements,
there
are
few
record
keeping
requirements
that
could
be
easily
automated.
As
a
result,
automated
record
keeping
appears
to
be
rare
among
respondents.
Some
regulatory
agencies
are
setting
up
electronic
reporting
systems
to
allow
sources
to
report
electronically
which
is
reducing
the
reporting
burden.
However,
electronic
reporting
systems
are
still
not
widely
used
by
the
regulatory
agencies.
It
is
believed
that
electronic
reporting
is
not
common
among
respondents2.

(
ii)
Respondent
Activities
Respondent
Activities
Read
instructions.

Install,
calibrate,
maintain,
and
operate
a
continuous
temperature
monitoring
device
for
thermal
or
catalytic
incinerators;
a
continuous
VOC
monitoring
device
for
regenerative
carbon
adsorbers;
and/
or
a
thermocouple
or
equivalent
device
for
flares,
as
applicable.

Perform
initial
performance
test,
Reference
Method
21
test
(
Method
22
for
flares),
and
repeat
performance
tests
if
necessary.

Write
the
notifications
and
reports
listed
above.

Enter
information
required
to
be
recorded
above.

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

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

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

Adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements.
Respondent
Activities
10
Train
personnel
to
be
able
to
respond
to
a
collection
of
information.

Transmit,
or
otherwise
disclose
the
information.

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

Agency
Activities
Observe
initial
performance
tests
and
repeat
performance
tests
if
necessary.

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

Audit
facility
records.

Input,
analyze,
and
maintain
data
in
the
Air
Facility
System
(
AFS).

5(
b)
Collection
Methodology
and
Management
Following
notification
of
startup,
the
reviewing
authority
may
inspect
the
source
to
check
if
the
pollution
control
devices
are
properly
installed
and
operated,
leaks
are
being
detected
and
repaired,
and
the
regulations
are
being
met.
Performance
test
reports
are
needed
as
these
are
the
Agency's
record
of
a
source's
initial
capability
to
comply
with
the
emission
standards,
and
serve
as
a
record
of
the
operating
conditions
under
which
compliance
was
achieved.
The
required
operating
conditions
for
enclosed
combustion
devices
are
a
VOC
destruction
efficiency
of
95
percent
or
greater,
and/
or
a
minimum
residence
time
of
0.75
seconds
at
a
minimum
temperature
of
1,500
degrees
Fahrenheit
(

F).
The
required
operating
condition
for
vapor
recovery
systems
(
e.
g.,
carbon
adsorbers)
is
a
VOC
recovery
efficiency
of
95
percent
or
greater.
The
required
operating
conditions
for
flares
are
no
visible
emissions
and
flame
must
be
present
at
all
times.
The
required
operating
condition
for
closed
vent
systems
is
for
emissions
to
be
non­
detectable.
Data
and
records
maintained
by
the
respondents
are
tabulated
and
published
for
use
in
compliance
and
enforcement
programs.
The
semiannual
reports
are
used
for
problem
identification,
as
a
check
on
2
Consultation
with
Norbert
Dee
and
Tom
Bigglesworth,
National
Petroleum
Refiners
Association.

11
source
operation
and
maintenance,
and
for
compliance
determinations.

Information
contained
in
the
reports
is
entered
into
the
AFS,
which
is
operated
and
maintained
by
EPA's
Office
of
Compliance.
AFS
is
EPA's
database
for
the
collection,
maintenance,
and
retrieval
of
compliance
data
for
approximately
125,000
industrial
and
government­
owned
facilities.
EPA
uses
the
AFS
for
tracking
air
pollution
compliance
and
enforcement
by
local
and
state
regulatory
agencies,
EPA
regional
offices
and
EPA
headquarters.
EPA
and
its
delegated
Authorities
can
edit,
store,
retrieve
and
analyze
the
data.

The
records
required
by
this
regulation
must
be
retained
by
the
owner
or
operator
for
two
years.

5(
c)
Small
Entity
Flexibility
A
majority
of
the
affected
facilities
are
large
entities
(
e.
g.,
large
businesses)
2.
However,
the
impact
on
small
entities
(
i.
e.,
small
businesses)
was
taken
into
consideration
during
the
development
of
the
regulation.
Due
to
technical
considerations
involving
the
process
operations
and
the
types
of
control
equipment
employed,
the
recordkeeping
and
reporting
requirements
are
the
same
for
both
small
and
large
entities.
The
Agency
considers
these
requirements
the
minimum
needed
to
ensure
compliance
and,
therefore,
cannot
reduce
them
further
for
small
entities.
To
the
extent
that
larger
businesses
can
use
economies
of
scale
to
reduce
their
burden,
the
overall
burden
will
be
reduced.

5(
d)
Collection
Schedule
The
specific
frequency
for
each
information
collection
activity
within
this
request
is
shown
in
Table
1:
Annual
Respondent
Burden
and
Cost,
NSPS
for
VOC
Emissions
From
Petroleum
Refinery
Wastewater
Systems
(
40
CFR
part
60,
subpart
QQQ).

6.
Estimating
the
Burden
and
Cost
of
the
Collection
Table
1
documents
the
computation
of
individual
burdens
for
the
recordkeeping
and
reporting
requirements
applicable
to
the
industry
for
the
subpart
included
in
this
ICR.
The
individual
burdens
are
expressed
under
standardized
headings
believed
to
be
consistent
with
the
concept
of
burden
under
the
Paperwork
Reduction
Act.
Where
appropriate,
specific
tasks
and
major
assumptions
have
been
identified.
Responses
to
this
information
collection
are
mandatory.

The
Agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
12
collection
of
information
unless
it
displays
a
currently
valid
OMB
Control
Number.

6(
a)
Estimating
Respondent
Burden
The
average
annual
burden
to
industry
over
the
next
three
years
from
these
recordkeeping
and
reporting
requirements
is
estimated
to
be
9,237
hours
(
Total
labor
hours
from
Table
1).
These
hours
are
based
on
Agency
studies
and
background
documents
from
the
development
of
the
regulation,
Agency
knowledge
and
experience
with
the
NSPS
program,
the
previously
approved
ICR,
and
any
comments
received.

6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
This
ICR
uses
the
following
labor
rates:

Managerial
$
95.32
($
45.39
+
110%)
Technical
$
64.60
($
30.76
+
110%)
Clerical
$
40.09
($
19.09
+
110%)

These
rates
are
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
December,
2003,
"
Table
10.
Private
industry,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
rates
have
been
increased
by
110%
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.

(
ii)
Estimating
Capital/
Startup
and
Operation
and
Maintenance
Costs
The
type
of
industry
costs
associated
with
the
information
collection
activities
in
the
subject
standards
are
both
labor
costs
which
are
addressed
elsewhere
in
this
ICR
and
the
costs
associated
with
continuous
monitoring.
The
capital/
startup
costs
are
one
time
costs
when
a
facility
becomes
subject
to
the
regulation.
The
annual
operation
and
maintenance
costs
are
the
ongoing
costs
to
maintain
the
monitors
and
other
costs
such
as
photocopying
and
postage.

The
estimated
respondent
burden
associated
with
capital/
startup
and
operation
and
maintenance
costs
has
decreased
to
less
than
the
current
OMB
inventory.
This
difference
is
the
result
of
a
reduction
in
the
number
of
existing
affected
sources,
a
reduction
in
the
number
of
new
sources,
the
inclusion
of
controls
other
than
flares,
and
revisions
to
operation
and
maintenance
costs.
Because
there
are
no
new
sources
expected,
capital/
startup
costs
are
expected
to
be
zero.

(
iii)
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
2
Consultation
with
Norbert
Dee
and
Tom
Bigglesworth,
National
Petroleum
Refiners
Association.

13
The
following
table
presents
the
respondent
costs
associated
with
capital/
startup,
and
operation
and
maintenance
of
the
control
devices
and
monitoring
systems
that
are
required
by
40
CFR
part
60,
subpart
QQQ:

Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
(
A)
Monitoring
Device
(
B)
Capital/
Startu
p
Cost
for
One
Respondent
(
C)
Number
of
New
Respondents
(
D)
Total
Capital/
Startu
p
Cost,
(
B
X
C)
(
E)
Annual
O&
M
Costs
for
One
Respondent
(
F)
Number
of
Respondents
with
O&
M
(
G)
Total
O&
M,

(
E
X
F)

Portable
VOC
analyzer
for
Nonregenerative
carbon
adsorber
$
2,960
0
$
0
$
130
135
$
17,550
Total
$
0
$
17,550
Cost
information
in
the
above
table
is
from
the
EPA
Air
Pollution
Control
Cost
Manual,
January
2002,
"
Table
4.10:
Cost
Summary
for
Parametric
Monitoring
of
VOCs
Using
Carbon
Adsorption
Capacity."
The
Agency
assumes
that
all
respondents
utilize
VOC
controls
to
comply
with
the
rule.
This
is
believed
to
be
a
conservative
estimate,
as
industry
consultation
indicates
that
some
respondents
use
covers
or
floating
roofs
to
avoid
the
requirements
for
closed­
vent
systems
and
control
devices2.
The
Agency
bases
the
cost
estimate
on
the
monitoring
of
nonregenerative
carbon
adsorbers
because
this
type
of
control
is
believed
to
be
common
among
respondents.

The
total
capital/
startup
costs
for
this
ICR
are
$
0.
This
is
the
total
of
column
D
in
the
above
table.
These
costs
are
shown
on
the
OMB
83­
I
form
in
block
14(
a),
Total
annualized
capital/
startup
costs.

The
total
operation
and
maintenance
(
O&
M)
costs
for
this
ICR
are
$
17,550.
This
is
the
total
of
column
G
and
for
reporting
purposes
will
be
rounded
off
to
$
17,600.
These
costs
are
shown
on
the
OMB
83­
I
form
in
block
14(
b),
Total
annual
costs
(
O&
M).

The
total
respondent
costs
in
block
14
have
been
calculated
as
the
addition
of
the
capital/
startup
costs,
and
the
annual
operation
and
maintenance
costs.
The
average
annual
cost
for
capital/
startup
and
operation
and
maintenance
costs
to
industry
over
the
next
three
years
of
2
Norbert
Dee
and
Tom
Bigglesworth,
National
Petroleum
Refiners
Association.

14
the
ICR
is
estimated
to
be
$
17,600.
This
cost
is
shown
on
the
OMB
83­
I
form
in
block
14(
c),
Total
annualized
cost
requested.
The
numbers
in
block
14
of
the
OMB
83­
I
form
are
rounded
to
show
the
cost
in
thousands
of
dollars.

6(
c)
Estimating
Agency
Burden
and
Cost
The
only
costs
to
the
Agency
are
those
costs
associated
with
analysis
of
the
reported
information.
EPA's
overall
compliance
and
enforcement
program
includes
activities
such
as
the
examination
of
records
maintained
by
the
respondents,
periodic
inspection
of
sources
of
emissions,
and
the
publication
and
distribution
of
collected
information.

The
average
annual
Agency
cost
during
the
three
years
of
the
ICR
is
estimated
to
be
$
98,254
[
See
Table
2
in
Section
6(
d)].

This
cost
is
based
on
the
average
hourly
labor
rate
as
follows:

Managerial
$
54.66
(
GS­
13,
Step
5,
$
34.16
x
1.6)
Technical
$
40.56
(
GS­
12,
Step
1,
$
25.35
x
1.6)
Clerical
$
21.95
(
GS­
6,
Step
3,
$
13.72
x
1.6)

These
rates
are
from
the
Office
of
Personnel
Management
(
OPM)
"
2004
General
Schedule,"
which
excludes
locality
rates
of
pay.
Details
upon
which
this
estimate
is
based
appear
in
Table
2:
Annual
Agency
Burden
and
Cost,
NSPS
for
VOC
Emissions
From
Petroleum
Refinery
Wastewater
Systems
(
40
CFR
Part
60,
Subpart
QQQ),
below.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Based
on
our
research
for
this
ICR,
approximately
135
existing
sources
are
currently
subject
to
the
standard.
It
is
estimated
that
no
additional
sources
will
become
subject
to
the
standard
in
the
next
three
years;
no
new
refineries
have
been
constructed
in
nearly
30
years,
and
existing
sources
rarely
need
to
construct
new
wastewater
facilities2.
None
of
the
existing
sources
have
new
facilities
(
no
change
year­
to­
year).
All
subject
sources
are
required
to
keep
records
and
submit
reports.
The
number
of
affected
sources
has
declined
in
recent
years
due
to
consolidation
and
closures
but
is
not
expected
to
decline
further
in
the
next
three
years.
15
The
number
of
respondents
is
calculated
using
the
following
table,
which
addresses
the
three
years
covered
by
this
ICR:

Number
of
Respondents
Respondents
That
Submit
Reports
Respondents
That
Do
Not
Submit
Any
Reports
Year
(
A)
Number
of
New
Respondents
1
(
B)
Number
of
Existing
Respondents
(
C)
Number
of
Existing
Respondents
that
keep
records
but
do
not
submit
reports
(
D)
Number
of
Existing
Respondents
That
Are
Also
New
Respondents
(
E)
Number
of
Respondents
(
E=
A+
B+
C­
D)

1
0
135
0
0
135
2
0
135
0
0
135
3
0
135
0
0
135
Average
0
135
0
0
135
1
New
respondents
include
sources
with
constructed,
reconstructed
and
modified
affected
facilities.
In
this
standard,
existing
respondents
submit
initial
notifications.

To
avoid
double­
counting
respondents,
column
D
is
subtracted.
As
shown
above,
the
average
Number
of
Respondents
over
the
three
year
period
of
this
ICR
is
135.
This
number
appears
on
the
OMB
83­
I
form
in
block
13(
a),
Number
of
respondents.

The
total
number
of
annual
responses
per
year
is
calculated
using
the
following
table:

Total
Annual
Responses
(
A)

Information
Collection
Activity
(
B)

Number
of
Respondents
(
C)

Number
of
Responses
(
D)
Number
of
Existing
Respondents
That
Keep
Records
But
Do
Not
Submit
Reports
(
E)
Total
Annual
Responses
E=(
BxC)+
D
Total
Annual
Responses
16
Notification
of
construction/
reconstruction
0
1
N/
A
0
Notification
of
modification
0
1
N/
A
0
Notification
of
actual
start­
up
0
1
N/
A
0
Initial
certification
of
equipment
and
inspections
0
1
N/
A
0
Initial
inspection
report
detailing
emission
problems
0
1
N/
A
0
Various
notifications
of
intent1
0
1
N/
A
0
Demonstration
for
alternative
operational
or
process
parameter
0
1
N/
A
0
Notification
of
delay
in
compliance
0
1
N/
A
0
Semiannual
report
135
2
0
270
Notification
of
initial
performance
test
0
1
N/
A
0
Total
270
1
This
includes
review
of
the
following
notifications:
election
to
construct
and
operate
a
completely
closed
drain
system;
election
to
construct
and
operate
a
floating
roof;
intent
to
use
an
alternative
means
of
emission
limitation;
and
intent
to
use
a
VOC
control
device
other
than
a
carbon
adsorber
to
meet
the
requirements
of
60.692­
5(
a).

The
number
of
Total
Annual
Responses
is
270.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
13(
b),
Total
annual
responses.

The
Total
Hours
Requested
is
shown
on
the
OMB
83­
I
form
in
block
13(
c).
The
total
annual
labor
costs
are
$
589,385.
The
annual
labor
costs
are
not
shown
on
the
OMB
83­
I
form.
Details
regarding
these
estimates
may
be
found
in
Table
1:
Annual
Respondent
Burden
and
Cost,
NSPS
for
VOC
Emissions
From
Petroleum
Refinery
Wastewater
Systems
(
40
CFR
part
60,
subpart
QQQ).

6(
e)
Bottom
Line
Burden
Hours
Burden
Hours
and
Cost
Tables
The
detailed
bottom
line
burden
hours
and
cost
calculations
for
the
respondents
and
the
17
Agency
are
shown
in
Tables
1
and
2,
respectively,
and
summarized
below.

(
i)
Respondent
Tally
The
Total
Hours
Requested
is
shown
on
the
OMB
83­
I
form
in
block
13(
c).
The
total
annual
labor
costs
are
$
589,385.
The
annual
labor
costs
are
not
shown
on
the
OMB
83­
I
form.
Details
regarding
these
estimates
may
be
found
in
Table
1:
Annual
Respondent
Burden
and
Cost,
NSPS
for
VOC
Emissions
From
Petroleum
Refinery
Wastewater
Systems
(
40
CFR
part
60,
subpart
QQQ).
Furthermore,
the
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
34.2
hours
per
response.

The
total
annual
capital/
startup
and
O&
M
costs
to
the
regulated
entity
are
$
17,500.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
14(
c),
Total
annualized
cost
requested.
The
cost
calculations
are
detailed
in
Section
6(
b)(
iii),
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs.

(
ii)
The
Agency
Tally
The
average
annual
Agency
burden
and
cost
over
the
next
three
years
is
estimated
to
be
2,484
labor
hours
at
a
cost
of
$
98,254.
See
Table
2:
Annual
Agency
Burden
and
Cost,
NSPS
for
VOC
Emissions
From
Petroleum
Refinery
Wastewater
Systems
(
40
CFR
part
60,
subpart
QQQ).

6(
f)
Reasons
for
Change
in
Burden
The
decrease
in
burden
from
the
most
recently
approved
ICR
is
due
to
adjustments.
The
adjustment
decrease
in
burden
from
the
most
recently
approved
ICR
is
primarily
due
to
a
decrease
in
the
number
of
sources
and
a
more
accurate
(
decreased)
estimate
of
the
number
of
anticipated
new
sources.
Because
there
are
no
new
sources
anticipated,
there
is
no
expected
burden
resulting
from
capital/
startup
costs,
initial
notifications,
or
initial
performance
tests.
These
revisions
led
to
decreases
in
burden
that
offset
increases
in
burden
resulting
from
other
revisions.
Revisions
leading
to
increases
in
burden
included
use
of
updated
labor
rates,
inclusion
of
managerial
and
clerical
hours
in
addition
to
technical
hours,
use
of
updated
O&
M
costs,
inclusion
of
O&
M
costs
for
control
devices
other
than
flares,
and
inclusion
of
burden
associated
with
notification
and
reporting
requirements
that
were
omitted
from
the
current
ICR.

The
estimated
respondent
burden
associated
with
capital/
startup
and
operation
and
maintenance
costs
has
decreased
to
less
than
the
current
OMB
inventory.
This
difference
is
the
result
of
a
reduction
in
the
number
of
existing
affected
sources,
a
reduction
in
the
number
of
new
sources,
the
inclusion
of
controls
other
than
flares,
and
revisions
to
operation
and
maintenance
costs.
Because
there
are
no
new
sources
expected,
capital/
startup
costs
are
expected
to
be
zero.
18
6(
g)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
34.2
hours
per
response.
Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.

An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
valid
OMB
Control
Number.
The
OMB
Control
Numbers
for
EPA's
regulations
are
listed
at
40
CFR
Part
9
and
48
CFR
chapter
15.

To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
Number
OECA­
2003­
0145,
which
is
available
for
public
viewing
at
the
Enforcement
and
Compliance
Docket
and
Information
Center
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Avenue,
NW,
Washington,
DC.
The
EPA
Docket
Center
Public
Reading
Room
is
open
from
8:
30
a.
m.
to
4:
30
p.
m.,
Monday
through
Friday,
excluding
legal
holidays.
The
telephone
number
for
the
Reading
Room
is
(
202)
566­
1744,
and
the
telephone
number
for
the
Enforcement
and
Compliance
Docket
and
Information
Center
is
(
202)
566­
1752.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
When
in
the
system,
select
"
search,"
then
key
in
the
Docket
ID
Number
identified
above.
Also,
you
can
send
comments
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Officer
for
EPA.
Please
include
the
EPA
Docket
ID
Number
OECA­
2003­
0145
and
OMB
Control
Number
2060­
0172
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
19
20
Table
1:
Annual
Respondent
Burden
and
Cost,
NSPS
for
VOC
Emissions
From
Petroleum
Refinery
Wastewater
Systems
(
40
CFR
part
60,
subpart
QQQ)

Activity
(
A)
Technical
Hrs/
Occurrence
(
B)
Occurrences/

Respondent/

Yr.
(
C)
Hours/
Respondent/

Yr.
(
D)
Number
of
Respondents
(
E)
Technical
Hrs/
Yr.

(
E
=
C
x
D)
(
F)
Management
Hours/
Yr.

(
F
=
0.05
x
E)
(
G)
Clerical
Hours/
Yr.

(
G
=
0.1
x
(
H)
Total
Labor
Costs/

1.
Applications
Not
applicable
2.
Survey
and
Studies
Not
applicable
3.
Reporting
Requirements
A.
Read
instructions
2
1
2
135
270
13.5
27
19,811
B.
Required
activities
i.
Inspect
drain
systems
2
12
24
135
3,240
162
324
237,735
ii.
Inspect
O/
W
separators
8
2
16
135
2,160
108
216
158,490
iii.
Performance
test
330
0
0
0
0
0
0
0
C.
Create
information
See
3B
D.
Gather
existing
information
See
3E
E.
Write
reports
i.
Notification
of
construction/

reconstruction
2
0
0
0
0
0
0
0
ii.
Notification
of
modification
2
0
0
0
0
0
0
0
iii.
Notification
of
actual
start­
up
2
0
0
0
0
0
0
0
iv.
Initial
certification
of
equipment
and
inspections
2
0
0
0
0
0
0
0
v.
Initial
inspection
report
detailing
emission
problems
2
0
0
0
0
0
0
0
vi.
Various
notifications
of
intent2
2
0
0
0
0
0
0
0
Activity
(
A)
Technical
Hrs/
Occurrence
(
B)
Occurrences/

Respondent/

Yr.
(
C)
Hours/
Respondent/

Yr.
(
D)
Number
of
Respondents
(
E)
Technical
Hrs/
Yr.

(
E
=
C
x
D)
(
F)
Management
Hours/
Yr.

(
F
=
0.05
x
E)
(
G)
Clerical
Hours/
Yr.

(
G
=
0.1
x
(
H)
Total
Labor
Costs/

21
vii.
Demonstration
for
alternative
operational
or
process
parameter
2
0
0
0
0
0
0
0
viii.
Notification
of
delay
in
compliance
2
0
0
0
0
0
0
0
ix.
Semiannual
report
8
2
16
135
2,160
108
216
158,490
x.
Notification
of
initial
2
0
0
0
0
0
0
0
xi.
Results
of
performance
test
See
3B
4.
Recordkeeping
Requirements
A.
Read
instructions
See
3A
B.
Plan
activities
Not
applicable
C.
Implement
activities
Not
applicable
D.
Develop
record
system
Not
applicable
E.
Enter
information
1.5
1
1.5
135
202.5
10.13
20.25
14,859
F.
Train
personnel
Not
applicable
G.
Perform
audits
Not
applicable
TOTAL
LABOR
BURDEN
AND
COST
(
rounded)
9,237
hours
$
589,385
1
This
cost
is
based
on
the
sum
of
personnel
hours
multiplied
by
their
hourly
labor
rates
[(
Technical
hours
x
$
64.60)
+
(
Management
hours
x
$
95.32)
+

(
Clerical
hours
x
$
40.09)].

2
This
includes
review
of
the
following
notifications:
election
to
construct
and
operate
a
completely
closed
drain
system;
election
to
construct
and
operate
a
floating
roof;
intent
to
use
an
alternative
means
of
emission
limitation;
and
intent
to
use
a
VOC
control
device
other
than
a
carbon
adsorber
to
meet
the
requirements
of
60.692­
5(
a).
22
Table
2:
Annual
Agency
Burden
and
Cost,
NSPS
for
VOC
Emissions
From
Petroleum
Refinery
Wastewater
Systems
(
40
CFR
part
60,
subpart
QQQ)

Activity
(
A)
Technical
Hrs/
Occurrence
(
B)
Occurrences/

Respondent/

Yr.
(
C)
Hours/
Respondent/
Yr.

(
C
=
A
x
B)
(
D)

#
Respondents
(
E)
Technical
Hrs/

Yr.

(
E
=
C
x
D)
(
F)
Management
Hours/
Yr.

(
F
=
0.05
x
E)
(
G)
Clerical
Hours/
Yr.

(
G
=
0.1
x
E)
(
H)

Total
Labor
Costs/
Yr.

($)
1
1.
Review
of
notification
of
construction/
reconstruction
2
0
0
0
0
0
0
0
2.
Review
of
notification
of
modification
2
0
0
0
0
0
0
0
3.
Review
of
notification
of
actual
start­
up
2
0
0
0
0
0
0
0
4.
Review
of
initial
certification
for
equipment
and
inspections
2
0
0
0
0
0
0
0
5.
Review
of
initial
inspection
report
detailing
emission
problems
2
0
0
0
0
0
0
0
6.
Review
of
various
notifications
of
intent2
2
0
0
0
0
0
0
0
7.
Review
of
demonstration
for
alternative
2
0
0
0
0
0
0
0
Activity
(
A)
Technical
Hrs/
Occurrence
(
B)
Occurrences/

Respondent/

Yr.
(
C)
Hours/
Respondent/
Yr.

(
C
=
A
x
B)
(
D)

#
Respondents
(
E)
Technical
Hrs/

Yr.

(
E
=
C
x
D)
(
F)
Management
Hours/
Yr.

(
F
=
0.05
x
E)
(
G)
Clerical
Hours/
Yr.

(
G
=
0.1
x
E)
(
H)

Total
Labor
Costs/
Yr.

($)
1
23
operational
or
process
parameter
8.
Review
of
notification
of
delay
in
compliance
2
0
0
0
0
0
0
0
9.
Review
of
notification
of
initial
performance
test
2
0
0
0
0
0
0
0
10.
Review
of
initial
performance
test
report
for
flares
2
0
0
0
0
0
0
0
11.
Attend
performance
test
120
0
0
0
0
0
0
0
12.
Attend
performance
retests3
188
0
0
0
0
0
0
0
13.
Review
of
semiannual
reports
8
2
16
135
2,160
108
216
98,254
TOTAL
LABOR
BURDEN
AND
COST
(
rounded)
2,484
hours
$
98,254
1
This
cost
is
based
on
the
sum
of
personnel
hours
multiplied
by
their
hourly
labor
rates
[(
Technical
hours
x
$
40.56)
+
(
Management
hours
x
$
54.66)
+

(
Clerical
hours
x
$
21.95)].

2
This
includes
review
of
the
following
notifications:
election
to
construct
and
operate
a
completely
closed
drain
system;
election
to
construct
and
operate
a
floating
roof;
intent
to
use
an
alternative
means
of
emission
limitation;
and
intent
to
use
a
VOC
control
device
other
than
a
carbon
adsorber
to
meet
the
requirements
of
60.692­
5(
a).

3
The
Agency
burden
of
188
person­
hours
per
retest
reflects
16
hours
for
a
notice
and
a
conference;
120
hours
to
attend
the
retest;
40
hours
for
compliance
order
preparation;
and
12
hours
for
delays
in
testing
that
occur
at
an
estimated
10%
of
retests.
