SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
The
Consolidated
Federal
Air
Rule
for
SOCMI
(
Renewal)

1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
The
Consolidated
Federal
Air
Rule
for
SOCMI
(
Renewal)

1(
b)
Short
Characterization/
Abstract
This
information
collection
request
(
ICR)
is
for
the
Consolidated
Federal
Air
Rule
(
CAR)
for
the
Synthetic
Organic
Chemical
Industry
(
SOCMI)
and
its
referencing
subparts.
EPA
will
use
this
information
to
ensure
compliance
with
the
provisions
in
the
CAR
and
its
referencing
subparts.

All
existing
sources
must
be
in
compliance
with
the
requirements
of
the
CAR
and/
or
its
referencing
subparts
within
three
years
of
the
effective
date
(
i.
e.,
promulgation
date)
of
the
appropriate
standard
for
the
affected
source.
All
new
sources
must
be
in
compliance
with
the
requirements
of
the
CAR
and/
or
its
referencing
subparts
upon
startup
or
the
promulgation
date
of
standards
for
an
affected
source,
whichever
is
later.
Compliance
is
assumed
through
initial
performance
testing
or
design
analysis,
as
appropriate,
and
ongoing
compliance
is
demonstrated
through
parametric
monitoring.
Types
of
parameters
monitored
are
incinerator
temperature,
scrubber
flow
rate,
carbon
adsorber
regeneration
frequency
as
well
as
others.
The
appropriate
parameter
to
monitor
depends
on
the
type
of
control
device
with
the
owner
or
operator
chooses
to
comply.

On
December
14,
2000,
the
CAR
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,
and
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.

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
2
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.
Because
the
CAR
is
designed
for,
although
not
limited
to,
SOCMI
facilities,
the
number
of
facilities
opting
to
comply
with
the
CAR
is
based
on
the
estimated
number
of
SOCMI
facilities.
It
is
estimated
that
25
percent
of
non­
Hazardous
Organic
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
HON)
sources
will
opt
to
comply
with
the
CAR
if
the
per­
source
burden
of
complying
with
the
CAR
is
less
than
the
per­
source
burden
of
complying
with
the
referencing
subpart.
For
those
referencing
subparts
for
which
the
per­
source
burden
of
complying
with
the
CAR
is
higher
than
the
per­
source
burden
of
complying
with
the
referencing
subpart
(
subparts
Ka,
Kb,
Y,
VV,
III,
NNN,
RRR,
and
DDD),
it
is
estimated
that
5
percent
of
sources
will
opt
to
comply
with
the
CAR.
It
is
also
estimated
that
25
percent
of
HON
sources
will
opt
to
comply
with
the
CAR.
It
is
assumed
that
all
new
sources
will
initially
comply
with
the
appropriate
referencing
subpart.

It
is
estimated
that
the
consolidated
collection
will
involve
3,913
respondents
with
11,447
annual
responses
and
Respondent
Labor
costs
of
$
131,358,704.
The
total
burden
is
estimated
to
be
2,057,270
hours
per
year.
Total
capital
costs
will
be
$
3,404,000
per
year
and
total
capital
and
O&
M
costs
will
be
$
95,360,000
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,
and
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
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
part
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
3
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,
for
which
construction,
reconstruction
or
modification
commenced
after
July
23,
1984.
There
are
exemptions
for
specific
storage
vessels
listed
in
40
CFR
part
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
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
was
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
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
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
polyethylene
(
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,
4
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
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.

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
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
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
5
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
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
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.
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)

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
6
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
coproduct
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
2(
a)
Need/
Authority
for
the
Collection
The
Clean
Air
Act
(
Act)
provides
authority
to
the
Agency
to
establish
standards
to
control
air
pollution
and
to
ensure
compliance
with
promulgated
regulations
through
adequate
recordkeeping
and
reporting
by
the
affected
industries
(
i.
e.,
respondents).
The
regulations
include
the
New
Source
Performance
Standards
(
NSPS)
under
section
111
of
the
Act,
the
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
which
includes
the
original
NESHAP
standards
and
the
more
recent
Maximum
Achievable
Control
Technology
(
MACT)
or
NESHAP­
MACT
standards
under
section
112
of
the
Act,
and
emission
guidelines
for
the
designated
types
incinerators
under
section
129
of
the
Act.

2(
b)
Practical
Utility/
Users
of
the
Data
The
recordkeeping
and
reporting
requirements
in
the
standard(
s)
are
used
by
regulatory
agencies,
the
public
and
the
regulated
community
for
a
variety
of
reasons
including
the
determination
of
the
respondent's
compliance
status,
analytical
studies
to
demonstrate
compliance
trends,
and
evaluations
regarding
the
efficacy
of
the
promulgated
regulations.

The
required
recordkeeping
and
reporting
are
also
used
to:
1)
certify
compliance
with
the
regulations;
2)
determine
the
respondent's
compliance
with
the
designated
emission
limitation(
s);
3)
notify
regulatory
agencies
when
a
standard
is
violated;
4)
evaluate
continuous
compliance
through
the
use
of
emission
or
operational
parameter
monitors;
and
5)
ensure
that
plant
personnel
are
following
the
required
procedures
and
are
periodically
trained,
as
indicated.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
3(
a)
Nonduplication
7
The
standards
do
not
require
the
duplication
in
the
collection
and
reporting
of
information.
If
the
subject
standards
have
not
been
delegated,
the
information
is
sent
directly
to
the
appropriate
Environmental
Protection
Agency
(
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.

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
(
69
FR
69909)
on
December
1,
2004.
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.

3(
c)
Consultations
Upon
review
of
the
standard,
information
available
and
the
data,
the
Agency
has
determined
the
recordkeeping
and
reporting
requirements
in
the
"
Active"
ICR
is
fully
supported
and
necessary
to
fulfil
the
requirements
of
the
Clean
Air
Act
(
CAA).
Any
pertinent
comments
received
since
the
last
ICR
renewal
including
those
submitted
in
response
to
the
First
Federal
Register
Notice
announcing
the
renewal
of
this
ICR,
have
been
reviewed,
and
it
has
been
determined
that
no
further
consultations
with
industry
are
necessary
to
calculate
the
burden
for
this
renewal.
It
should
be
noted
that
the
respondents,
the
industry
trade
association(
s)
and
other
interested
parties
were
provided
an
opportunity
to
comment
on
the
burden
associated
with
the
standard
as
it
was
being
developed.

3(
d)
Effects
of
Less
Frequent
Collection
The
effect
of
less
frequent
collection
would
be
a
decrease
in
the
margin
of
assurance
that
facilities
are
achieving
the
emission
reductions
mandated
by
the
CAA
through
the
promulgation
of
the
applicable
regulations.
In
addition,
the
likelihood
of
detecting
the
poor
operation
and
maintenance
of
control
equipment
decreases
and
the
detection
of
noncompliance
becomes
problematic.

3(
e)
General
Guidelines
Neither
the
reporting
nor
recordkeeping
requirements
violate
the
regulations
established
by
Office
of
Management
and
Budget
(
OMB)
at
5
CFR
part
1320,
Section
1320.5.
However,
most
NESHAP
standards
and
a
few
NSPS
standards
require
records
to
be
kept
more
than
three
years.
In
general,
these
standards
require
the
respondents
to
maintain
all
records,
including
reports
and
notifications,
for
five
years.
The
five­
year
record
retention
requirement
is
consistent
with
the
permit
program
at
40
CFR
part
70,
and
the
five­
year
statute
of
limitations
on
which
the
permit
program
is
based.
8
The
retention
of
records
for
five
years
allows
EPA
to
establish
the
compliance
history
of
the
respondent
for
purposes
of
determining
the
appropriate
level
of
enforcement
action.
Historically,
EPA
notes
that
the
most
flagrant
violations
have
extended
beyond
a
five­
year
period.
If
records
are
retained
for
less
than
five
years,
EPA
would
be
deterred
from
pursuing
the
most
flagrant
violations
due
to
the
destruction
of
records
documenting
noncompliance.

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
The
recordkeeping
and
reporting
requirements
do
not
contain
sensitive
questions.

4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
SIC
Codes
The
Standard
Industrial
Classification
(
SIC)
codes
and
corresponding
North
American
Industry
Classification
System
(
NAICS)
for
the
respondents
are
listed
below.

SIC
Code
NAICS
Code
2821
325211
2824
325222
2851
32551
2865
325111,
325132,
325192
2869
32511,
325193,
325199
2899
32511,
325199
2911
32411
2951
324121
2952
324122
2992
324191
SIC
Code
NAICS
Code
9
2999
324199
4212
562111,
562112,
562119,
48411,
48421,
48422
4213
484121,
484122,
48421,
48423
4214
48411,
48421,
48422
4215
49211,
49221
4221
49313
4222
49312
4225
49311,
53113
4226
49312,
49311,
49319
4231
48849
4412
483111
4424
483113
4432
483113
4449
483211
4481
483112,
483114
4482
483114,
483212
4489
483212,
48721
4491
48831,
48832
4492
48833
4493
71393
4499
532411,
48831,
48833,
48839
4724
56151
4725
56152
4729
488999,
561599
4731
541614,
48851
SIC
Code
NAICS
Code
10
4741
532411,
48821
4783
488991
4785
48839,
48849
4789
488999,
48711,
72231,
48821
This
table
is
not
meant
to
be
exhaustive,
but
rather
provides
a
guide
for
readers
regarding
the
entities
likely
to
be
regulated
by
this
standard.
To
determine
whether
the
standard
applies
to
a
particular
entity,
please
see
the
applicability
provisions
in
the
standard.

4(
b)
Information
Requested
(
i)
Data
Items
Attachment
A
lists
the
recordkeeping
and
reporting
requirements
for
the
CAR
and
the
referencing
subparts.

Electronic
Reporting
At
the
present,
many
respondents
to
CAA
standards
use
monitoring
equipment
that
automatically
records
parameter
data.
Although
personnel
at
the
affected
facility
must
evaluate
the
data,
this
internal
automation
has
significantly
reduced
the
burden
associated
with
monitoring
and
recordkeeping
at
the
plant
site.

Also
regulatory
agencies,
in
cooperation
with
the
respondents,
continue
to
create
reporting
systems
to
transmit
data
electronically.
However,
electronic
reporting
systems
are
still
not
widely
used.
At
this
time,
it
is
estimated
that
approximately
20
percent
of
the
respondents
use
electronic
reporting.

(
ii)
Respondent
Activities
Respondent
Activities
Read
instructions.

Install,
calibrate,
maintain,
and
operate
CPMS
for
the
appropriate
control
device
Perform
initial
performance
test
and
repeat
performance
tests
if
necessary.

Write
the
notifications
and
reports
listed
in
Attachment
A
Enter
information
required
to
be
recorded
in
Attachment
A.
Respondent
Activities
11
Submit
the
required
reports
developing,
acquiring,
installing,
and
utilizing
technology
and
systems
for
the
purpose
of
collecting,
validating,
and
verifying
information.

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

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

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

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

Transmit,
or
otherwise
disclose
the
information.

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

The
Agency
activities
associated
with
the
CAR
are
presented
in
Table
3,
and
the
Agency
activities
associated
with
the
referencing
subparts
are
shown
in
Tables
F1
through
F11.

5(
b)
Collection
Methodology
and
Management
The
required
data
and
reports
can
be
evaluated
on­
site
by
conducting
a
partial
compliance
evaluation,
full
compliance
evaluation
or
inspection,
or
thru
an
off­
site
review
of
compliance
monitoring
records
and
reports.
Evaluation
reports
and
inspection
results
are
maintained
by
the
Agency
or
delegated
authority.

The
results
of
these
evaluations
are
entered
into
the
Air
Facility
Subsystem
(
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
delegated
authorities
can
retrieve
and
analyze
the
data.

5(
c)
Small
Entity
Flexibility
12
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.

5(
d)
Collection
Schedule
The
specific
frequency
for
each
information
collection
activity
within
this
request
is
shown
in
Table
6
for
the
CAR
and
Tables
G1
­
G12
for
the
referencing
subparts,
respectively.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
Table
6
for
the
CAR,
and
Tables
G1­
G12
for
the
referencing
subparts,
document
the
computation
of
individual
burdens
for
the
recordkeeping
and
reporting
requirements
applicable
to
the
industry.
The
individual
burdens
are
expressed
under
standardized
headings
believed
to
be
consistent
with
the
concept
of
burden
under
the
Paperwork
Reduction
Act.
Where
appropriate,
specific
tasks
and
major
assumptions
have
been
identified.
Responses
to
this
information
collection
are
mandatory.

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

6(
a)
Estimating
Respondent
Burden
The
respondent
burden
is
summarized
in
Table
7
and
detailed
in
Table
6
for
the
CAR,
and
Tables
G1­
G12,
for
the
referencing
subparts.
The
labor
hours
are
based
on
Agency
studies
and
background
documents
from
the
development
of
the
regulation,
Agency
knowledge
and
experience
with
the
standard,
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
$
96.41
($
45.91
+
110%)
Technical
$
82.74
($
39.40
+
110%)
Clerical
$
42.25
($
20.12
+
110%)
13
These
rates
are
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
September
2004,
"
Table
2.
Civilian
Workers,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
rates
have
been
increased
by
110
percent
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.

(
ii)
Estimating
Capital/
Startup
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
summarized
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
J.

(
iii)
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
The
total
capital/
startup
costs
for
this
ICR
are
detailed
in
Appendix
J
and
summarized
in
Table
7
in
column
F.
This
is
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
is
the
total
of
column
E.
This
is
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
costs
for
capital/
startup
and
operation
and
maintenance
costs
to
industry
over
the
next
three
years
of
the
ICR
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
Costs
The
only
costs
to
the
Agency
are
those
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
and
the
publication
and
distribution
of
collected
information.

The
average
annual
Agency
burden
and
cost
during
the
three
years
of
the
ICR
is
27,994
hours
and
$
1,134,891.
This
is
calculated
in
Table
3
for
the
CAR
and
Attachments
F1­
F11
for
the
referencing
subparts,
and
is
summarized
in
Table
7.

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

Managerial
$
56.02
(
GS­
13,
Step
5,
$
35.01
x
1.6)
14
Technical
$
41.57
(
GS­
12,
Step
1,
$
25.98
x
1.6)
Clerical
$
22.50
(
GS­
6,
Step
3,
$
14.06
x
1.6)

These
rates
are
from
the
Office
of
Personnel
Management
(
OPM)
"
2004
General
Schedule"
which
excludes
locality
rates
of
pay.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Number
of
respondents
is
calculated
in
Table
6
for
the
CAR,
and
Attachments
G1­
G12
for
the
referencing
subparts
for
the
three
years
covered
by
this
ICR
and
summarized
in
Column
(
B)
of
Table
7.
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).
A
summary
of
the
total
annual
labor
cost
may
be
found
in
Table
7.
A
detailed
description
of
the
Total
Hours
Requested
may
be
found
in
Table
6
for
the
CAR,
and
Attachments
G1­
G12
for
the
referencing
subparts.

The
average
annual
Agency
burden
and
cost
over
next
three
years
is
shown
in
Table
3
for
the
CAR,
and
Tables
F1
­
F11
for
the
referencing
subparts.

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
Agency
are
summarized
in
Table
7
and
detailed
in
Tables
3
and
6
for
the
CAR,
and
Tables
F1
­
F11
and
G1
­
G12
for
the
referencing
subparts,
respectively.

(
i)
Respondent
Tally
The
Total
Hours
Requested
is
shown
on
the
OMB
83­
I
form
in
block
13(
c).
The
annual
labor
cost
is
not
shown
on
the
OMB
83­
I
form.
Details
regarding
these
estimates
may
be
found
in
Table
6
for
the
CAR,
and
Tables
F1
­
F11
and
G1
­
G12
for
the
referencing
subparts,
respectively.
Furthermore,
the
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
180
hours
per
response.

The
total
annual
capital/
startup
and
O&
M
costs
to
the
regulated
entity
are
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)
Cost.

(
ii)
The
Agency
Tally
The
average
annual
Agency
burden
hours
and
cost
over
next
three
years
is
27,994
hours
at
a
cost
of
$
1,134,891.
This
is
summarized
in
Table
7
and
detailed
in
Table
3
for
the
CAR
and
15
Tables
F1
­
F11
for
the
referencing
subparts.

6(
f)
Reasons
for
Change
in
Burden
There
is
a
decrease
of
108,330
burden
hours
from
the
most
recently
approved
ICR
due
to
adjustments.
35,758
hours
of
the
adjustments
are
a
program
change
for
NSPS
subparts
Kb,
VV,
DDD,
III,
NNN
and
RRR
(
Tables
G2
­
G7),
which
no
longer
require
Notifications
of
Anticipated
Startup.
The
balance
of
the
adjustments
(
72,572
hours)
are
due
primarily
to
the
corrections
of
errors
and
the
addition
of
clerical
and
managerial
hours
to
the
burden
calculation.
All
tables
were
updated
with
new
labor
rates.
Additional
specific
changes
are
as
follows:

Table
3
­
Item
3
in
Column
(
b)
was
changed
to
reflect
the
number
of
facilities,
not
sources,
submitting
periodic
reports.
Facilities
will
combine
periodic
reports
from
multiple
sources,
so
this
is
a
more
accurate
number.

Table
5
­
The
entry
for
technical
hour
burden
to
"
File/
Store"
was
reduced
for
process
vents
from
approximately
one
hour
per
month
to
one
quarter
hour
per
month.
This
decrease
was
taken
due
to
our
experience
that
one
hour
per
month
is
an
overstatement
of
the
burden
and
one
quarter
hour
more
accurately
reflects
industry
practice.
One
quarter
hour
is
also
consistent
with
other
recently
approved
ICR's
for
the
Clean
Air
Act.
A
corresponding
reduction
in
burden
was
taken
for
storage
tanks,
transfer
racks,
equipment
leaks
and
inventory.

Table
6
­
The
entry
in
Columns
(
a),
(
c)
and
(
d)
for
the
technical
hour
burden
to
"
File/
Store"
was
reduced
consistent
with
the
change
in
Table
5.

Table
7
­
Since
this
is
a
summary
table,
the
appropriate
entries
were
changed
according
to
the
changes
made
to
Tables
3
­
6,
Tables
F1
­
F11
and
G1
­
G12.
Columns
were
added
to
include
the
Agency
burden
in
hours
and
cost.
Additionally,
the
total
annual
responses
for
the
CAR
were
incorrectly
calculated
in
the
previous
ICR
and
are
corrected
here.

Tables
F1
and
G1
­
The
10
percent
reduction
for
Ka
sources
using
the
CAR
rule
was
removed
as
this
has
already
been
counted
in
the
CAR
tables
and
in
the
previous
ICR.
The
number
of
plants
per
year
performing
a
seal
gap
measurement
for
external
floating
roofs
was
corrected
to
include
both
the
number
of
sources
performing
a
secondary
seal
gap
measure
(
157)
and
a
primary
seal
gap
measure
(
31)
for
a
total
of
188.
The
entry
for
the
number
of
sources
reporting
seal
gaps
was
also
in
error
in
the
previous
ICR.
The
previous
ICR
included
a
report
for
each
of
the
sources
using
an
external
floating
roof
tank.
Based
our
experience
with
seal
gap
excess
reports
received
by
the
delegated
authority,
it
is
more
reasonable
to
assume
that
only
3
percent
of
these
sources
(
6)
will
have
to
report
a
seal
gap
excess.
For
Table
G1,
the
entry
for
primary
seal
gap
measurements
was
in
error
in
the
previous
ICR.
The
assumption
is
that
20
percent
of
the
157
external
floating
roof
tanks,
or
31,
will
perform
primary
seal
gap
measurements.
The
entry
for
the
number
of
sources
16
recording
a
fill/
refill
of
the
tank
was
also
in
error
in
the
previous
ICR.
The
correct
number
is
20
percent
of
the
174
tanks
using
either
an
internal
or
external
floating
roof,
or
35.
The
number
of
respondents
was
incorrectly
determined
in
the
previously
approved
ICR
as
it
included
a
notification
of
the
fill/
refill
activity.
No
such
report
is
required
under
NSPS
subpart
Ka;
only
a
record
must
be
maintained.
Table
G1
was
also
updated
to
remove
the
burden
associated
with
the
Notification
for
Anticipated
Startup.
This
is
no
longer
a
requirement
under
the
NSPS
rules.
The
F1
and
G1
tables
were
also
updated
to
include
clerical
and
managerial
burden.

Table
F2
­
A
mathematical
error
in
the
Technical
Hours
for
the
Review
of
Notification
of
Delay
of
Repair/
Emptying
for
Internal
Floating
Roofs
(
IFR's)
was
corrected.
The
table
was
updated
to
include
clerical
and
managerial
burden.

Table
F3
­
The
table
was
updated
to
delete
expenses
associated
with
travel
to
view
performance
tests.
These
costs
are
not
consistent
with
the
concept
of
burden.
A
typographical
error
was
corrected
in
Column
(
a)
under
Notification
of
Construction.
Table
F3
was
also
updated
to
remove
the
burden
associated
with
the
Notification
for
Anticipated
Startup.
This
is
no
longer
a
requirement
for
NSPS
rules.
The
table
was
also
updated
to
include
clerical
and
managerial
burden.

Tables
F4
to
F7
­
The
tables
were
updated
to
delete
expenses
associated
with
travel
and
technical
hours
to
view
performance
tests.
These
costs
are
not
consistent
with
the
concept
of
burden.
The
tables
were
also
updated
to
remove
the
burden
associated
with
the
Notification
for
Anticipated
Startup.
This
is
no
longer
a
requirement
under
the
NSPS
rules.
To
avoid
losing
a
significant
figure
due
to
rounding,
the
assumption
for
the
percentage
of
sources
performing
repeat
performance
tests
(
20
percent)
was
moved
to
the
entry
for
Column
(
B),
Occurrences
per
year.
The
tables
were
also
updated
to
include
clerical
and
managerial
burden.

Table
F8
­
The
table
was
updated
to
delete
expenses
associated
with
travel
and
technical
hours
to
view
performance
tests.
These
costs
are
not
consistent
with
the
concept
of
burden.
The
tables
were
also
updated
to
include
clerical
and
managerial
burden.

Table
F9
­
The
table
was
updated
to
delete
expenses
associated
with
travel
and
technical
hours
to
view
performance
tests.
These
costs
are
not
consistent
with
the
concept
of
burden.
The
entries
for
the
number
of
plants
per
year
for
Notification
of
Control
Installation
and
Refill
After
First
Degassing,
Annual
IFR
Internal
Inspections
and
External
Floating
Roof
(
EFR)
Seal
Gap
Measurements,
and
Supplemental
Delay
Report
were
corrected
from
the
previous
ICR.
The
previous
ICR
did
not
incorporate
the
updated
assumptions
made
in
the
corresponding
respondent
burden
Table
G9.
The
tables
were
also
updated
to
include
clerical
and
managerial
burden.

Table
F10
­
The
table
was
updated
to
delete
expenses
associated
with
travel
and
technical
17
hours
to
view
performance
tests.
These
costs
are
not
consistent
with
the
concept
of
burden.
The
number
of
plants
per
year,
from
the
previous
ICR,
was
also
corrected
for
all
entries.
The
previous
ICR
never
incorporated
the
updated
assumptions
made
in
the
corresponding
respondent
burden
Table
G10.
To
avoid
losing
a
significant
figure
due
to
rounding,
the
assumption
for
the
percentage
of
sources
performing
repeat
performance
tests
(
20
percent)
was
moved
to
the
entry
for
Column
(
B),
Occurrences
per
year.
The
tables
were
also
updated
to
include
clerical
and
managerial
burden.

Table
F11
­
The
entry
for
the
Number
of
Activities
per
year
to
Review
Equipment
Leak
Monitoring
was
corrected
from
the
previous
ICR.
The
correct
number
should
be
the
number
of
sources
complying
with
the
rule
(
240).
Regardless
of
the
number
of
components
in
the
leak
detection
and
repair
program,
each
source
will
only
submit
one
report
to
cover
all
components.
The
table
was
also
updated
to
include
clerical
and
managerial
burden.

Table
G2
­
A
mathematical
error
in
Column
(
D)
for
Notification
of
Delay
of
Repair
or
Emptying
for
Internal
Floating
Roofs
(
IFRs)
was
corrected.
Table
G2
was
also
updated
to
remove
the
burden
associated
with
the
Notification
for
Anticipated
Startup.
This
is
no
longer
a
requirement
under
the
NSPS
rules.
The
number
of
responses
was
recalculated
to
include
only
those
items
requiring
a
report
or
a
notification.
The
table
was
also
updated
to
include
clerical
and
managerial
burden.

Tables
G3
and
G4
­
Tables
G3
and
G4
were
updated
to
remove
the
burden
associated
with
the
Notification
for
Anticipated
Startup.
This
is
no
longer
a
requirement
under
the
NSPS
rules.
The
number
of
responses
was
recalculated
to
include
only
those
items
requiring
a
report
or
a
notification.
The
tables
were
updated
to
include
clerical
and
managerial
burden.

Table
G5
to
G7
­
The
entries
for
Record
of
Operating
Parameters
for
Control
Devices
and
Records
of
Operating
Conditions
Exceeding
Last
Performance
Test
were
changed
to
reflect
the
technical
burden
on
a
monthly
basis
which
is
consistent
with
how
the
records
are
generated.
Records
of
Start­
up,
shutdown
and
malfunction
were
exaggerated
in
the
previous
ICR
and
have
been
reduced
downward
to
more
accurately
reflect
actual
incidence
of
startup,
shutdown,
and
malfunction.
Tables
G5
­
G7
were
updated
to
remove
the
burden
associated
with
the
Notification
for
Anticipated
Startup.
This
is
no
longer
a
requirement
under
the
NSPS
rules.
The
tables
were
also
updated
to
include
clerical
and
managerial
burden.

Table
G8
­
A
mathematical
error
was
corrected
in
Column
(
C)
under
Quarterly
Parameter
Excesses
and
Facilities
above
cut­
off.
The
table
was
also
updated
to
include
clerical
and
managerial
burden.

Table
G9
­
A
mathematical
error
was
corrected
in
Column
(
E)
under
Supplemental
Delay
18
Report.
The
previously
approved
ICR
inadvertently
omitted
the
data
entries
for
Notification
of
Control
Installation
and
Refill
at
1st
IFR
Degassing,
for
new
sources.
The
appropriate
burden
was
reintroduced
into
the
table.
The
table
was
also
updated
to
include
clerical
and
managerial
burden.

Table
G10
­
The
entry
for
Column
(
C)
for
Semiannual
reports,
Records
of
operating
parameters
and
emissions,
and
Records
of
leaks
detected
was
corrected
to
the
correct
number
of
sources.

Table
G12
­
The
Total
Annual
Responses
was
calculated
incorrectly
in
the
previous
ICR.
The
total
annual
responses
should
include
the
total
of
HON
sources
complying
(
240)
plus
the
CAR
sources
complying
with
HON
wastewater
(
80).

There
is
a
decrease
in
the
Total
Capital/
Startup
and
Operation
and
Maintenance
Costs
of
$
4,561,000.
Specifically,
the
Total
Capital/
Startup
and
Operation
and
Maintenance
Costs
were
changed
for
NSPS
subpart
Kb.
The
previous
ICR
included
the
costs
on
installing
new
storage
tanks
with
external
floating
roofs.
This
is
not
consistent
with
the
concept
of
capital/
startup
costs
under
the
PRA.
The
correct
capital/
startup
costs
are
only
those
associated
with
monitoring
equipment.
It
is
assumed
that
only
a
portion
of
the
new
sources
will
install
a
closed
vent
system
to
a
control
device;
the
balance
will
use
floating
roofs,
which
will
not
require
equipment
monitoring.
The
cost
for
monitors
from
NSPS
subpart
NNN
was
used
as
the
basis
for
estimating
capital/
startup
costs,
as
these
tanks
will
likely
be
co­
located
at
NSPS
subpart
NNN
facilities
and
use
similar
control
technology.
A
corresponding
correction
was
performed
for
operation
and
maintenance
cost
for
subpart
Kb.
Additionally,
a
math
error
in
the
calculation
of
Capital/
Startup
Costs
and
Total
Capital/
Startup
and
O&
M
Costs
for
subpart
G
of
the
HON
was
corrected.

6(
g)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
180
hours
per
response.
Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
disclose,
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
to
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;
to
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
to
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
to
search
data
sources;
to
complete
and
review
the
collection
of
information;
and
to
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.
19
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
2004­
0049,
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
Ave.,
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
OECA
Docket
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,
to
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.
You
can
also
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
2004­
0049
and
OMB
Control
Number
2060­
0443
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
20
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
21
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
22
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
Costd
(
f)

1.
Initial
Notification
of
Part
65
Applicability
2
27
e
54
3
5
$
2,518
2.
Review
Equipment
Leak
Monitoring
5
636
f
3180
159
318
$
148,255
3.
Review
Periodic
Reports
4
80
g
320
16
32
$
14,919
TOTAL
ANNUAL
COST
3554
178
355
$
165,692
Total
Annual
Burden
4087
a
c
=
a
x
b
b
Estimate
managerial
hours
are
5
percent
of
technical
hours.
c
Estimate
clerical
hours
are
10
percent
of
technical
hours.
d
Annual
cost
is
the
sum
of
costs
for
technical,
managerial,
and
clerical
hours
based
on
rates
from
the
Office
of
Personnel
Management
(
OPM)
"
2004
General
Schedule"
which
excludes
locality
rates
of
pay.
Technical
­
$
41.57
(
GS­
12,
Step
1,
$
25.98
x
1.6)
Managerial
­
$
56.02
(
GS­
13,
Step
5,
$
35.01
x
1.6)
Clerical
$
22.50
(
GS­
6,
Step
3,
$
14.06
x
1.6)
e
Estimate
that
all
CAR
sources
must
submit
an
Initial
Notification
of
Part
65
Applicability.
It
is
estimated
that
1/
3
of
the
sources
will
submit
in
initial
notification
in
each
of
the
three
years
covered
by
this
ICR.
This
equates
to
27
per
year
(
80/
3)
during
each
of
the
three
years
following
promulgation.
f
Estimate
that
318
equipment
leak
sources
will
comply
with
the
CAR
(
240
from
the
HON,
59
from
subpart
VV
and
19
from
subpart
V
­
see
Table
4).
Reports
for
Equipment
leaks
will
be
submitted
semiannually
(
318
x
2
=
636
per
year).
See
Attachment
C
for
assumptions
and
further
description
of
activities.
g
Estimate
that
25
percent
of
the
320
SOCMI
facilities
which
equals
80
facilities
will
opt
to
comply
with
the
CAR
and
must
submit
periodic
reports
each
year.
23
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
(
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
F
&
G
­
Storage
Vessels
800
HON
F
&
G
­
Transfer
Racks
320
HON
H
&
I
­­
Equipment
Leaks
240
HON
F
&
G
­
Process
Vents
640
a
Note
that
the
estimate
is
on
a
per­
source
basis,
rather
than
on
a
facility
basis
and
therefore
correlates
to
(
as
described
in
the
footnote
to
the
appropriate
Table),
but
does
not
match
the
facility
entries
in
the
referencing
subpart
burden
tables
in
Tables
F1­
F11
and
G1­
G12.
For
the
purpose
of
this
information
collection
request,
a
source
is
defined
as:


one
storage
vessel
(
subparts
Ka,
Kb,
Y,
and
G);


one
process
vent
(
subparts
DDD,
III,
NNN,
RRR,
and
G);


the
collection
of
subject
equipment
for
one
process
unit
(
subparts
VV,
V,
and
H
&
I);
or

one
transfer
rack
(
subparts
BB
and
G).
b
From
the
most
recently
approved
ICR.
24
TABLE
5:
BASIS
FOR
ANNUAL
RESPONDENT
BURDEN
OF
REPORTING
AND
RECORDKEEPING
FOR
THE
CAR
Burden
Item
Annual
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
5,097
.
Training
1.3
943
0.5
820
0.5
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
6,525
5.4
8,856
5.4
1,728
57
13,680
23
1,794
5.4
432
33,015
Burden
Item
Annual
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
25
.
Record/
Disclose
28
20,300
2.8
4,592
2.8
896
4.7
1,128
1.9
148
9
720
27,784
.
File/
Store
3
2,175
1.25
2,050
1.25
400
2.75
660
0.9
70
1.58
126
5,482
TOTAL
88.3
64,018
46
75,030
45
14,368
711
170,525
290
22,622
94
7,542
354,106
a
The
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.

c
Total
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
d
Total
burden
for
each
burden
item
is
the
sum
of
totals
for
each
source
type.
This
burden
represents
technical
hours
only
and
is
the
basis
for
determining
total
burden
in
Table
6.
26
TABLE
6:
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
(
g)

Read
Rule
and
Instructions
2.76
23
63.51
5,081
254
508
$
466,353
Plan
Activities
4.90
13
63.71
5,097
255
510
$
467,858
Training
6.01
4
24.04
1,923
96
192
$
176,476
Create,
Test,
Research
and
Development
19.56
99
1936.88
154,950
7,748
15,495
$
14,222,211
Gather
Information,

Monitor
and
Inspect
2.20
677
1491.68
119,334
5,967
11,933
$
10,953,143
Compile,
Process
and
Review
Data
18.00
1
18.00
1,440
72
144
$
132,171
Complete
Forms
82.54
5
412.69
33,015
1,651
3,302
$
3,030,344
Record/
Disclose
13.36
26
347.30
27,784
1,389
2,778
$
2,550,132
File/
Store
1.96
35
68.53
5,482
274
548
$
503,150
TOTAL
COST
354,106
17,706
35,410
$
32,501,838
TOTAL
BURDEN
HOURS
407,222
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,
with
a
reduction
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
5,
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.
27
(
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
rates
from
the
United
States
Department
of
Labor,

Bureau
of
Labor
Statistics,
September
2004,
"
Table
2.
Civilian
Workers,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
rates
have
been
increased
by
110
percent
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.

Managerial
$
96.41
($
45.91
+
110%)

Technical
$
82.74
($
39.40
+
110%)

Clerical
$
42.25
($
20.12
+
110%)
28
TABLE
7:
SUMMARY
OF
RESPONDENT
BURDEN
AND
COST
FOR
REFERENCING
SUBPARTS
AND
THE
CAR
Subpart
(
A)
Number
of
Respondents
(
Block
13a)
(
B)

Total
Annual
Responses
(
Block
13b)
a
(
C)
Respondent
Burden
Hours
(
Block
13c)
(
D)
Respondent
Burden
Costs
(
E)
Agency
Burden
Hours
(
F)
Agency
Burden
Costs
(
E)

Total
Capital
and
O&
M
(
Block
14
c)
in
000'
sb
(
F)

Capital
Costs
(
Block
14a)

in
000'
sb
NSPS
Ka
174
194
46,455
$
3,707,733
115
$
4,646
0
0
NSPS
Kb
580
1,976
85,489
$
6,823,252
978
$
39,636
69
27
NSPS
VV
1,120
2,610
119,635
$
9,548,494
6,071
$
246,096
35
35
NSPS
DDD
90
222
6,755
$
539,133
571
$
23,144
930
300
NSPS
III
11
26
296
$
23,636
69
$
2,778
29
14
NSPS
NNN
1,345
3,433
41,880
$
3,342,654
8,955
$
363,067
4,206
2,390
NSPS
RRR
155
394
4,789
$
382,236
1,026
$
41,604
578
500
NESHAP
BB
54
216
12,444
$
993,255
497
$
20,140
0
0
NESHAP
Y
4
8
65
$
5,176
9
$
373
0
0
NESHAP
V
55
123
7,529
$
600,869
289
$
11,710
0
0
NESHAP
F,
G,

H,
and
I
245
1,845
1,324,711
$
72,890,428
5,327
$
216,005
67,513
138
CAR
80
400
407,222
$
32,501,838
4,087
$
165,692
22,000
0
TOTAL
3,913
11,447
2,057,270
$
131,358,704
27,994
$
1,134,891
95,360
3,404
a
From
Tables
G1­
G11
b
From
Appendix
J
A1
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.
A2
°
Low­
throughput
transfer
operation
records
where
emissions
are
controlled
by
a
control
device
as
specified
in
§
§
65.159
and
65.163.

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.
A3
°
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.

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).
A4
°
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).

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).

°
Submit
notification
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).
A5
°
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).

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
A6
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
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
A7
§
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
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
A8
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
A9
position
has
changed.
A
record
of
the
serial
number
of
the
car­
seal
or
a
record
to
show
that
the
key
to
unlock
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).
A10
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.

°
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).
A11
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).

°
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)

Notifications:

°
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.
A12
°
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.

°
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
A13
§
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.
B1
Attachment
B
Purposely
left
blank.
C1
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
*
$
41.57/
hour)
+
(
Hm
*
$
56.02/
hour)
+
(
Hc
*
$
14.06/
hour)
=
(
h)

1,000
C2
Where:
Ht
is
(
c),
or
technical
hours,

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

Source:

Annual
cost
is
the
sum
of
costs
for
technical,
managerial,
and
clerical
hours
based
on
rates
from
the
Office
of
Personnel
Management
(
OPM)
"
2004
General
Schedule"
which
excludes
locality
rates
of
pay.

Technical
­
$
41.57
(
GS­
12,
Step
1,
$
25.98
x
1.6)

Managerial
­
$
56.02
(
GS­
13,
Step
5,
$
35.01
x
1.6)

Clerical
$
22.50
(
GS­
6,
Step
3,
$
14.06
x
1.6)

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).
D1
Attachment
D
Purposely
left
blank.
E1
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
calculated
in
Table
5
and
entered
into
column
(
c),
(
a)
is
then
back­
calculated
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,

colocated
readings,
etc.
Since
so
much
variability
exists,
it
is
important
to
note
that
this
an
estimate.
This
number
was
only
used
E2
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.

(
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
*
$
82.74/
hour)
+
(
Hm
*
$
96.41/
hour)
+
(
Hc
*
$
42.25/
hour)=(
g)

Where:

Ht
is
(
d),
or
technical
hours,

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

Source:
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
September
2004,
"
Table
2.
Civilian
Workers,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
rates
have
been
increased
by
110
percent
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.

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.
E3
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.

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).
F1
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
(
E=
CxD)
Technical
hr/
yr
(
F=
Ex0.05)

Managerial
Hr/
yr
(
G=
Ex0.10)

Clerical
Hr/
Yr
(
H)
Total
Cost
per
yeare
Report
Review:
New
Plant
Vapor
recoveryb
N/
A
Report
Review:

Existing
Plant
Notification
of
Reconstruction
2
1
2
0
0
0
0
$
0
Notification
of
Modification
2
1
2
0
0
0
0
$
0
Notification
of
seal
gap
measurement
c
0.5
1
0.5
188
94
5
9
$
4,389
Report
of
gap
excessesc,
d
1
1
1
6
6
0
1
$
257
TOTAL
ANNUAL
HOURS
100
5
10
TOTAL
ANNUAL
BURDEN
115
$
4,646
a
Assume
no
new
sources
subject
to
this
regulation.
All
similar
new
sources
will
be
subject
to
Subpart
Kb.

b
Required
only
at
start
of
construction.
Any
new
storage
vessel
being
constructed
would
be
subject
to
the
NSPS
Subpart
Kb.
F2
c
Assume
that
90
percent
of
the
storage
vessels
will
use
a
floating
roof
and
be
subject
to
seal
gap
measurement.
The
remaining
10
percent
will
use
a
closed
vent
system.

d
Assume
25
percent
of
respondents
using
a
floating
roof
will
have
excessive
seal
gaps
requiring
that
a
single
report
be
filed
once
per
year.

e
Annual
cost
is
the
sum
of
costs
for
technical,
managerial,
and
clerical
hours
based
on
rates
from
the
Office
of
Personnel
Management
(
OPM)
"
2004
General
Schedule"
which
excludes
locality
rates
of
pay.

Technical
­
$
41.57
(
GS­
12,
Step
1,
$
25.98
x
1.6)

Managerial
­
$
56.02
(
GS­
13,
Step
5,
$
35.01
x
1.6)

Clerical
­
$
22.50
(
GS­
6,
Step
3,
$
14.06
x
1.6)
F3
TABLE
F.
2:
AVERAGE
ANNUAL
EPA
RESOURCE
REQUIREMENT
FOR
SUBPART
Kb
Reporting
and
Recordkeeping
Requirements
Assumptionsa
(
A)
Technical
Hours
(
B=
A*.
05)
Managerial
Hours
(
C=
A*.
10)

Clerical
Hours
Cost/
year
$
a
1)
Review
notification
of
construction.
37b
new
notifications
at
2
hours
each
74
4
7
$
3,458
2)
Review
notice
of
anticipated
startup.
37
new
notifications
at
1
hour
each
37
2
4
$
1,740
3)
Review
notice
of
actual
startup.
37
new
notifications
at
1
hour
each
37
2
4
$
1,740
4)
Review
notification
of
initial
inspection
@
1
hr.
each
37
2
4
$
1,740
5)
Review
of
IFR
Failure
Reportc;
55
sources
@
1
hr/
ea
55
3
6
$
2,589
6)
Review
Notification
of
Delay
for
Repair/
Emptying
IFRd;
6
sources@
1.2
hr/
ea
7
0
1
$
313
7)
Review
Notification
to
Re­
Filld
;
602
sources@
1
hr/
ea
602
30
60
$
28,056
TOTAL
ANNUAL
HOURS
849
43
86
TOTAL
ANNUAL
BURDEN
978
$
39,636
a
Annual
cost
is
the
sum
of
costs
for
technical,
managerial,
and
clerical
hours
based
on
rates
from
the
Office
of
Personnel
Management
(
OPM)
"
2004
General
Schedule"
which
excludes
locality
rates
of
pay.

Technical
­
$
41.57
(
GS­
12,
Step
1,
$
25.98
x
1.6)
F4
Managerial
­
$
56.02
(
GS­
13,
Step
5,
$
35.01
x
1.6)

Clerical
­
$
22.50
(
GS­
6,
Step
3,
$
14.06
x
1.6)

b
Assume
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).

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

d
From
Table
G.
2
F5
TABLE
F.
3:
AVERAGE
ANNUAL
EPA
RESOURCE
REQUIREMENT
FOR
SUBPART
VV
Activity
(
A)

EPA/
hr
Occurrence
(
B)
Occurrences/

plant/
yr
(
C)
Plants/

year
(
D)
a
Technical
hr/
yr
(
E=
F*.
05)
Managerial
hrs/
yr
(
G=
F*.
10)

Clerical
hrs/
yr
Cost/
yre
Report
Review
New
Plant
Notification
of
Construction
8
1
56b
448
22
45
$
20,868
Notification
of
Reconstruction/
Modification
2
1
28
56
3
6
$
2,631
Notification
of
Actual
Startup
0.5
1
84
42
2
4
$
1,948
Notification
of
Initial/
Repeat
Test
0.5
1
101c
51
3
5
$
2,380
Review
Test
Results
2
1
101c
202
10
20
$
9,407
Existing
Plants
Semiannual
Emission
Reportse
2
2
1120d
4,480
224
448
$
208,862
TOTAL
ANNUAL
HOURS
5,279
264
528
TOTAL
ANNUAL
BURDEN
6,071
$
246,096
a
D=
AxBxC
b
Estimate
that
there
are
84
new
affected
sources
(
56
new
affected
sources
will
be
due
to
construction
and
28
will
be
reconstructed
or
modified).

c
Assume
20
percent
of
performance
tests
are
repeated
due
to
failure
F6
d
There
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.

e
Annual
cost
is
the
sum
of
costs
for
technical,
managerial,
and
clerical
hours
based
on
rates
from
the
Office
of
Personnel
Management
(
OPM)
"
2004
General
Schedule"
which
excludes
locality
rates
of
pay.

Technical
­
$
41.57
(
GS­
12,
Step
1,
$
25.98
x
1.6)

Managerial
­
$
56.02
(
GS­
13,
Step
5,
$
35.01
x
1.6)

Clerical
­
$
22.50
(
GS­
6,
Step
3,
$
14.06
x
1.6)

.
F7
TABLE
F.
4:
ANNUAL
AVERAGE
EPA
RESOURCE
REQUIREMENT
FOR
SUBPART
DDD
Activity
(
A)

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

plants/
year
(
D)
a
Technical
hrs/
yr
(
E=
D*.
05)
Managerial
hrs/
hr
(
F=
E*.
10)

Clerical
hrs/
yr
(
G)
b
Cost/
yr
($)

Report
Review
Notification
of
Construction/

Reconstruction/
Modification
2
1
10
20
1
2
$
932
Notification
of
Actual
Startup
2
1
10
20
1
2
$
932
Initial
Performance
Test
8
1
10
80
4
8
$
3,730
Repeat
Performance
Testd
8
0.2
10
16
1
2
$
766
Semiannual
Reports
2
2
90c
360
18
36
$
16,784
TOTAL
ANNUAL
HOURS
496
25
50
TOTAL
ANNUAL
BURDEN
571
$
23,144
a
D=
AXBXC
b
Annual
cost
is
the
sum
of
costs
for
technical,
managerial,
and
clerical
hours
based
on
rates
from
the
Office
of
Personnel
Management
(
OPM)
"
2004
General
Schedule"
which
excludes
locality
rates
of
pay.

Technical
­
$
41.57
(
GS­
12,
Step
1,
$
25.98
x
1.6)

Managerial
­
$
56.02
(
GS­
13,
Step
5,
$
35.01
x
1.6)

Clerical
­
$
22.50
(
GS­
6,
Step
3,
$
14.06
x
1.6)

c
Average
number
of
affected
sources
over
next
three
years.

d
Assume
20
percent
of
performance
tests
repeated
due
to
failure
F8
TABLE
F.
5:
AVERAGE
ANNUAL
EPA
RESOURCE
REQUIREMENT
FOR
SUBPART
III
Activity
(
A)

EPA
hr/
Occurrence
(
B)
Occurrences/

plant/
yr
(
C)
Plants/
yr
(
D)
a
Technical
hr/
yr
(
E=
D*.
05)
Managerial
hrs/
hr
(
F=
E*.
10)

Clerical
hrs/
yr
(
G)
b
Cost/
yr
($)

Report
Review
New
Plant
­
Notification
of
Construction/
Reconstruction/
Modification
2
1
1
2
0.1
0.20
$
93
Notification
of
Anticipated
Startup
2
1
1
2
0.1
0.20
$
93
Notification
of
Actual
Startup
2
1
1
2
0.1
0.20
$
93
Initial
Test
8
1
1
8
0.4
0.80
$
373
Repeat
Performance
Testc
8
0.2
1
1.6
0.08
0.16
$
75
Semiannual
Reports
2
2
11d
44
2.2
4.40
$
2,051
TOTAL
ANNUAL
HOURS
59.6
2.98
5.96
TOTAL
ANNUAL
BURDEN
69
$
2,778
a
D=
AxBxC
b
Annual
cost
is
the
sum
of
costs
for
technical,
managerial,
and
clerical
hours
based
on
rates
from
the
Office
of
Personnel
Management
(
OPM)
"
2004
General
Schedule"
which
excludes
locality
rates
of
pay.

Technical
­
$
41.57
(
GS­
12,
Step
1,
$
25.98
x
1.6)

Managerial
­
$
56.02
(
GS­
13,
Step
5,
$
35.01
x
1.6)

Clerical
­
$
22.50
(
GS­
6,
Step
3,
$
14.06
x
1.6)

c
Assume
20
percent
of
performance
tests
are
repeated
due
to
failure
d
Average
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.
F9
TABLE
F.
6:
AVERAGE
ANNUAL
EPA
RESOURCE
REQUIREMENT
FOR
SUBPART
NNN
Activity
(
A)

EPA
hr/
Occurrence
(
B)
Occurrences/

plant/
yr
(
C)
Plants/
yr
(
D)
a
Technical
hr/
yr
(
E=
D*.
05)
Managerial
hrs/
hr
(
F=

E*.
10)
Clerical
hrs/
yr
(
G)
b
Cost/
yr
($)

Report
Review
New
Plant
­
Notification
of
Construction/
Reconstruction/
Modification
2
1
177
354
18
35
$
16,512
Notification
of
Actual
Startup
2
1
177
354
18
35
$
16,512
Initial
Test
8
1
177
1416
71
142
$
66,036
Repeat
Performance
Testc
8
0.2
177
283
14
28
$
13,187
Semiannual
Reports
2
2
1345d
5380
269
538
$
250,821
TOTAL
ANNUAL
HOURS
7787
390
778
TOTAL
ANNUAL
BURDEN
8955
$
363,067
a
D=
AxBxC
b
Annual
cost
is
the
sum
of
costs
for
technical,
managerial,
and
clerical
hours
based
on
rates
from
the
Office
of
Personnel
Management
(
OPM)
"
2004
General
Schedule"
which
excludes
locality
rates
of
pay.

Technical
­
$
41.57
(
GS­
12,
Step
1,
$
25.98
x
1.6)

Managerial
­
$
56.02
(
GS­
13,
Step
5,
$
35.01
x
1.6)

Clerical
­
$
22.50
(
GS­
6,
Step
3,
$
14.06
x
1.6)

c
Assume
20
percent
of
performance
tests
are
repeated
due
to
failure
d
Average
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.
F10
TABLE
F.
7:
AVERAGE
ANNUAL
EPA
RESOURCE
REQUIREMENT
FOR
SUBPART
RRR
Activity
(
A)

EPA
hr/
Occurrence
(
B)
Occurrences/

plant/
yr
(
C)
Plants/

year
(
D)
a
Technical
hr/
yr
(
E=
D*.
05)
Managerial
hr/
yr
(
F=
E*.
10)

Clerical
hr/
yr
(
G)

Cost/
yr
$
b
Report
Review
New
Plant
­
Notification
of
Construction/
Reconstruction/

Modification
2
1
20
40
2
4
$
1,865
Notification
of
Actual
Startup
2
1
20
40
2
4
$
1,865
Initial
Test
8
1
20
160
8
16
$
7,459
Repeat
Performance
Testc
8
0.2
20
32
2
3
$
1,510
Semiannual
Reports
2
2
155d
620
31
62
$
28,905
TOTAL
ANNUAL
HOURS
892
45
89
TOTAL
ANNUAL
BURDEN
1026
$
41,604
a
D=
AxBXC
b
Annual
cost
is
the
sum
of
costs
for
technical,
managerial,
and
clerical
hours
based
on
rates
from
the
Office
of
Personnel
Management
(
OPM)
"
2004
General
Schedule"
which
excludes
locality
rates
of
pay.

Technical
­
$
41.57
(
GS­
12,
Step
1,
$
25.98
x
1.6)

Managerial
­
$
56.02
(
GS­
13,
Step
5,
$
35.01
x
1.6)

Clerical
­
$
22.50
(
GS­
6,
Step
3,
$
14.06
x
1.6)

c
Assume
20
percent
of
performance
tests
are
repeated
due
to
failure.

d
Average
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.
F11
TABLE
F.
8:
AVERAGE
ANNUAL
EPA
RESOURCE
REQUIREMENT
FOR
SUBPART
BB
Activity
(
A)

EPA/
hr
Occurrence
(
B)
Occurrences/

plant/
yr
(
C)
b
Plants/
year
(
D)
Technical
hrs/
yra
(
E=
D*.
05)
c
Managerial
hr/
yr
(
F=
D*.
1)

Clerical
hr/
yr
(
G)

Cost/
yr
$
d
Report
Review
New
Plantc
Notification
of
construction
0.5
0
0
0
0
0
$
0
Notification
of
anticipated
startup
0.5
0
0
0
0
0
$
0
Notification
of
actual
startup
0.5
0
0
0
0
$
0
Initial
report
8
0
0
0
0
0
$
0
Notification
of
emission
test
0.5
0
0
0
0
0
$
0
Result
of
emission
test
4
0
0
0
0
0
$
0
Notification
of
performance
test
0.5
0
0
0
0
0
$
0
Result
of
performance
test
8
0
0
0
0
0
$
0
Review
test
results
8
0
0
0
0
0
$
0
F12
Report
Review
Existing
Plant
Quarterly
reports
2
4
54
432
22
43
$
20,140
TOTAL
ANNUAL
HOURS
432
22
43
TOTAL
ANNUAL
BURDEN
497
$
20,140
a
AxBxC=
D
b
Assume
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.

c
Assume
no
new
sources.

d
Annual
cost
is
the
sum
of
costs
for
technical,
managerial,
and
clerical
hours
based
on
rates
from
the
Office
of
Personnel
Management
(
OPM)
"
2004
General
Schedule"
which
excludes
locality
rates
of
pay.

Technical
­
$
41.57
(
GS­
12,
Step
1,
$
25.98
x
1.6)

Managerial
­
$
56.02
(
GS­
13,
Step
5,
$
35.01
x
1.6)

Clerical
­
$
22.50
(
GS­
6,
Step
3,
$
14.06
x
1.6)
F13
TABLE
F.
9:
AVERAGE
ANNUAL
EPA
RESOURCE
REQUIREMENT
FOR
SUBPART
Y
Activity
(
A)

EPA/
hr
Occurrence
(
B)
Occurrences/

plant/
yr
(
C)
a
Plants/
yr
(
D)
Technical
hr/
yrb
(
E=
D*.
05)

Managerial
hr/
yr
(
F=
D*.
10)

Clerical
hr/
yr
(
G)

Cost/
yr
$
c
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
degassingd
1
1
0
0
0
0
$
0
Existing
Plant
Annual
IFR
internal
inspections
and
EFR
seal
gap
measurements
2
1
4
8
0
1
$
373
Supplemental
delay
reporte
1
1
0
0
0
0
$
0
F14
Quarterly
emission
reportsf
N/
A
N/
A
N/
A
N/
A
N/
A
N/
A
N/
A
TOTAL
ANNUAL
HOURS
8
0.4
0.8
TOTAL
ANNUAL
BURDEN
9
$
373
a
Estimate
that
there
are
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.

b
D=
AxBxC
c
Annual
cost
is
the
sum
of
costs
for
technical,
managerial,
and
clerical
hours
based
on
rates
from
the
Office
of
Personnel
Management
(
OPM)
"
2004
General
Schedule"
which
excludes
locality
rates
of
pay.

Technical
­
$
41.57
(
GS­
12,
Step
1,
$
25.98
x
1.6)

Managerial
­
$
56.02
(
GS­
13,
Step
5,
$
35.01
x
1.6)

Clerical
­
$
22.50
(
GS­
6,
Step
3,
$
14.06
x
1.6
d
It
is
believed
that
all
vessels
have
been
degassed
and
all
controls
have
been
installed
as
they
were
to
have
been
installed
within
10
years
of
promulgation
(
1999)

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

f
Assume
that
no
source
will
select
the
fixed
roof
vented
to
a
control
device
option
and
thus
have
no
quarterly
report
of
excess
emissions.
F15
TABLE
F.
10:
AVERAGE
ANNUAL
EPA
RESOURCE
REQUIREMENT
FOR
SUBPART
V
Activity
(
A)

EPA
hr/
Occurrence
(
B)
Occurrences/

plant/
yr
(
C)

Plants/
yearb
(
D)
a
Technical
hr/
yr
(
E=
D*.
05)
Managerial
hr/
yr
(
F=
E*.
10)

Clerical
hr/
yr
(
G)

Cost/
yr
$
d
Report
Review
New
Plant
­
Notification
of
Construction/
Reconstruction/

Modification
2
1
2
4
0.20
0.40
$
186
Notification
of
Anticipated
Startup
2
1
2
4
0.20
0.40
$
186
Notification
of
Actual
Startup
2
1
2
4
0.20
0.40
$
186
Initial
Test
8
1
2
16
0.80
1.60
$
746
Repeat
Performance
Testc
8
0.2
2
3
0.16
0.32
$
149
Semiannual
Reports
2
2
55
220
11.00
22.00
$
10,257
TOTAL
ANNUAL
HOURS
251
13
25
TOTAL
ANNUAL
BURDEN
289
$
11,710
a
AxBxC=
D
b
Assume
2
new
sources
per
year
at
one
new
facility
and
55
existing
process
units
subject
to
NESHAP
V,
but
not
the
HON.

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

d
Annual
cost
is
the
sum
of
costs
for
technical,
managerial,
and
clerical
hours
based
on
rates
from
the
Office
of
Personnel
Management
(
OPM)
"
2004
General
Schedule"
which
excludes
locality
rates
of
pay.

Technical
­
$
41.57
(
GS­
12,
Step
1,
$
25.98
x
1.6)

Managerial
­
$
56.02
(
GS­
13,
Step
5,
$
35.01
x
1.6)

Clerical
­
$
22.50
(
GS­
6,
Step
3,
$
14.06
x
1.6
F16
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
©
)
Estimated
Managerial
Hours
per
year
(
d)
Estimated
Clerical
Hours
per
year
(
e)
Annual
Cost
$

(
f)

REPORTS
REVIEW:

1)
Initial
2
5
10
1
1
$
494
2)
Implementation
Plan
or
Permit
20
5
100
5
10
$
4,662
3)
Compliance
status
40
5
200
10
20
$
9,325
4)
Review
equipment
leak
monitoring
7
240
1680
84
168
$
78,327
5)
Notification
of
Construction/
Reconstruction.
2
5
10
1
1
$
494
6)
Notification
of
anticipated
startup
2
5
10
1
1
$
494
7)
Notification
of
actual
startup
2
5
10
1
1
$
494
8)
Notification
of
Performance
Test
2
5
10
1
1
$
494
9)
Review
of
test
results
8
5
40
2
4
$
1,865
10)
Review
periodic
reports
4
640
2560
128
256
$
119,356
TOTAL
ANNUAL
HOURS
4630
234
463
TOTAL
ANNUAL
BURDEN
5327
$
216,005
See
Attachment
H
for
assumptions
and
further
description
of
activities.
G1
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)
a
Plants/
year
(
D)
Technical
hr/
yr
(
E=
D*.
05)

Managerial
hr/
yr
(
F=
D*.
10)

Clerical
hr/
yr
(
G)

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
0
0
0
0
$
0
Measure
seal
gap
Included
in
4E
C.
Create
Information
Included
in
3B
D.
Gather
Existing
Information
1
1
157c
157
8
16
$
14,437
E.
Write
Report
Notification
of
construction
2
1
0
0
0
0
$
0
(
A)

hr/
Occurrence
(
B)
Occurrences/

plant/
yr
(
C)
a
Plants/
year
(
D)
Technical
hr/
yr
(
E=
D*.
05)

Managerial
hr/
yr
(
F=
D*.
10)

Clerical
hr/
yr
(
G)

Cost/
yrb
G2
Notification
of
actual
startup
2
1
0
0
0
0
$
0
Notification
of
gap
measurement
1.5
1
188c
282
14
28
$
25,865
Report
of
seal
gap
excess
2.5
1
6d
15
1
2
$
1,422
Information
on
vapor
recovery
Included
in
3B.

Total
Annual
Responses
(
Block
13b)
194
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
E.
Time
to
Enter
Information
(
A)

hr/
Occurrence
(
B)
Occurrences/

plant/
yr
(
C)
a
Plants/
year
(
D)
Technical
hr/
yr
(
E=
D*.
05)

Managerial
hr/
yr
(
F=
D*.
10)

Clerical
hr/
yr
(
G)

Cost/
yrb
G3
New
tank
seal
gap
measurements
250
1
0
0
0
0
$
0
Secondary
seal
gap
measurement
250d,
e
1
157c
39,250
1,963
3,925
$
3,602,629
Primary
seal
gap
measurements
100d
0.2f
31c
620
31
62
$
56,907
Fill/
refill
record
2h
1
35
g
70
4
7
$
6,473
TOTAL
ANNUAL
HOURS
40,394
2,021
4,040
TOTAL
ANNUAL
BURDEN
46,455
$
3,707,733
a
Assume
that
there
will
be
no
new
source
subject
to
the
requirements
of
this
regulation.
Similar
new
sources
will
be
subject
to
NSPS
Subpart
Kb.
There
are
174
existing
sources
with
an
average
of
50
tanks
per
facility.

b
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
September
2004,
"
Table
2.
Civilian
Workers,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
rates
have
been
increased
by
110
percent
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.
Technical
­
$
82.47/
hr;
Managerial
­
$
96.41/
hr;
Clerical
­

$
42.25/
hr
c
Estimate
that
10
percent
of
respondents
(
17)
will
use
a
vapor
recovery
control
system
and
90
percent
(
157)
will
use
a
floating
roof
system.
Respondents
using
vapor
recovery
control
are
not
required
to
do
seal
gap
measurements.
All
of
the
tanks
using
floating
roof
(
157)
will
perform
a
secondary
seal
gap
measurement.
20
percent
(
31)
will
conduct
a
primary
seal
gap
measurement.
157
+
31
=

188
respondents
submitting
a
notification
of
either
primary
or
secondary
gap
measurement.

d
Assume
that
3
percent
of
respondents
using
a
floating
roof
will
have
excessive
seal
gaps
(
primary
or
secondary)
requiring
that
a
single
report
be
filed
once
a
year.
G4
e
Estimate
five
hours
to
conduct
secondary
seal
measurements
annually
for
the
average
50
tanks
per
respondent.

f
Estimate
two
hours
to
conduct
primary
seal
measurements
every
five
years
for
the
average
50
tanks
per
respondent.

g
During
any
one
year,
a
respondent
would
change
liquid
in
approximately
20
percent
of
the
facilities
(
35).

h
Estimate
0.2
hours
to
record
a
liquid
change
per
tank
in
20
percent(
10)
of
the
average
of
50
tanks
per
facility.
G5
TABLE
G.
2:
ANNUAL
BURDEN
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
FOR
SUBPART
Kb
(
A)

hr/
Occurrence
(
B)
Occurrences/

plant/
yr
(
C)
a
Plants/

yr
(
D)
Technical
hr/
yr
(
E=
D*.
05)

Managerial
hr/
yr
(
F=
D*.
10)

Clerical
hr/
yr
(
G)

$
Cost/
yr
1.
Applications
N/
A
2.
Surveys
and
Studies
N/
A
3.
Reporting
Requirements
A.
Read
Instruction
1
1
37d
37
2
4
$
3,423
B.
Required
Activities
One­
Time
Only
Requirements
Notification
of
Start
of
Construction
2
1
37
74
4
7
$
6,804
Notification
of
Actual
Startup
2
1
37
74
4
7
$
6,804
Notification
of
Physical
or
Operational
Changesc
N/
A
Notification
of
Malfunctionc
N/
A
Notification
of
Initial
Inspection
(
A)

hr/
Occurrence
(
B)
Occurrences/

plant/
yr
(
C)
a
Plants/

yr
(
D)
Technical
hr/
yr
(
E=
D*.
05)

Managerial
hr/
yr
(
F=
D*.
10)

Clerical
hr/
yr
(
G)

$
Cost/
yr
G6
IFR
Internal
Inspection
2
1
28d
56
3
6
$
5,176
EFR
Gap
Measurement
2
1
7
d
14
1
1
$
1,297
Initial
Inspection
Report
IFR
Internal
Inspection
Report
12
1
28d
336
17
34
$
30,876
EFR
2nd
Seal
Gap
Measurement
8
1
7
56
3
6
$
5,176
EFR
1st
Seal
Gap
Measurement
12
1
7
84
4
8
$
7,674
CVS
Operating
Plan
Report
8
1
2
16
1
2
$
1,505
Repeat
Requirements
Internal
IFR
Inspectione
12
1
116
1,392
70
139
$
127,796
Visual
IFR
Inspectione
8
1
464
3,712
186
371
$
340,738
Report
of
IFR
Failuref
2
1
55
110
6
11
$
10,145
(
A)

hr/
Occurrence
(
B)
Occurrences/

plant/
yr
(
C)
a
Plants/

yr
(
D)
Technical
hr/
yr
(
E=
D*.
05)

Managerial
hr/
yr
(
F=
D*.
10)

Clerical
hr/
yr
(
G)

$
Cost/
yr
G7
Notification
of
Delay
of
Repair
or
Emptying
for
IFRg
4
1
6
24
1
2
$
2,167
EFR
2nd
Seal
Gap
Measure
Report
8
1
580
4,640
232
464
$
425,885
EFR
1st
Seal
Gap
Measure
Report
12
1
580
6,960
348
696
$
638,827
Notification
of
Refillh
2
1
602
1,204
60
120
$
110,474
Number
of
Responses
(
Block
13b)
1976
4.
RECORDKEEPING
REQUIREMENTS
A.
Read
Instructions
1
1
37
37
2
4
$
3,423
B.
Gather
and
Record
Information
i.
Vessel
Volumes,

Liquid
Vapor
Pressure,
flares
8
1
580
4,640
232
464
$
425,885
ii.
113b(
a)
inspection
12
1
580
6,960
348
696
$
638,827
iii.
113b(
b)
gap
measurement
12
1
580
6,960
348
696
$
638,827
(
A)

hr/
Occurrence
(
B)
Occurrences/

plant/
yr
(
C)
a
Plants/

yr
(
D)
Technical
hr/
yr
(
E=
D*.
05)

Managerial
hr/
yr
(
F=
D*.
10)

Clerical
hr/
yr
(
G)

$
Cost/
yr
G8
C.
Develop
Record
System
10
1
3
30
2
3
$
2,802
D.
Time
to
Enter
Information
­
CVS
Parameter
Records
2
52
355
36,920
1,846
3,692
$
3,388,721
F.
Train
Personnel
N/
A
G.
Audits
N/
A
TOTAL
ANNUAL
HOURS
74,336
3,720
7,433
TOTAL
ANNUAL
BURDEN
85,489
$
6,823,252
a
Estimate
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.

b
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
September
2004,
"
Table
2.
Civilian
Workers,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
rates
have
been
increased
by
110
percent
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.
Technical
­
$
82.47/
hr;
Managerial
­
$
96.41/
hr;
Clerical
­

$
42.25/
hr
c
The
General
Provision
notifications
of
modification
or
malfunction
will
be
covered
by
notification
within
the
subpart.

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

e
For
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.
These
activities
are
required
to
generate
the
information
for
the
IFR
failure
report
and
the
EFR
primary
and
secondary
seal
gap
reports,
but
do
not
generate
a
response
for
the
purposes
of
the
total
for
Block
13b.

f
One
percent
failure
rate
for
the
5468
IFRs
choosing
annual
visual
inspections
equals
approximately
55.
G9
g
Ten
percent
of
55
failed
IFRs
are
delayed
in
repair
or
emptying
equals
approximately
6.

h
Assume
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.
G10
TABLE
G.
3:
ANNUAL
BURDEN
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
FOR
SUBPART
VV
Activity
(
A)
Hours/
Occurrence
(
B)
Occurrences/

respondent/

year
(
C)
a
Respondents/
yr
(
D)
Technical
hr/
yr
(
E=
D*.
05)

Managerial
hr/
yr
(
F=
D*.
10)

Clerical
hr/
yr
(
G)

$
Cost/
yr
1.
Applications
N/
A
2.
Survey
and
Studies
N/
A
3.
Reporting
Requirements
A.
Read
Instructions
1
1
84
84
4
8
$
7,674
B.
Required
Activities
Initial
Performance
Test
Report
48
1
84
4,032
202
403
$
370,109
Repeat
Performance
Test
Report
48
1
17c
816
41
82
$
74,933
C.
Create
Information
Included
in
3B
D.
Gather
Existing
Information
Included
in
3E
E.
Write
Report
New
Sources
Notification
of
Construction
2
1
56
112
6
11
$
10,310
Activity
(
A)
Hours/
Occurrence
(
B)
Occurrences/

respondent/

year
(
C)
a
Respondents/
yr
(
D)
Technical
hr/
yr
(
E=
D*.
05)

Managerial
hr/
yr
(
F=
D*.
10)

Clerical
hr/
yr
(
G)

$
Cost/
yr
G11
Notification
of
Reconstruction/

Modification
2
1
28
56
3
6
$
5,176
Notification
of
Actual
Startup
2
1
84
168
8
17
$
15,390
Notification
of
Initial/
Repeat
Performance
Test
2
1
101
202
10
20
$
18,523
Existing
Sources
Semiannual
Report
4
2
1120
8,960
448
896
$
822,398
Total
Annual
Responses
(
Block
13b)
2610
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
Activity
(
A)
Hours/
Occurrence
(
B)
Occurrences/

respondent/

year
(
C)
a
Respondents/
yr
(
D)
Technical
hr/
yr
(
E=
D*.
05)

Managerial
hr/
yr
(
F=
D*.
10)

Clerical
hr/
yr
(
G)

$
Cost/
yr
G12
E.
Time
to
Enter
Information
Records
of
Operating
Parameters
80
1
1120
89,600
4,480
8,960
$
8,223,981
F.
Train
personnel
N/
A
G.
Audits
N/
A
TOTAL
ANNUAL
HOURS
104,030
5,202
10,403
TOTAL
ANNUAL
BURDEN
119,635
$
9,548,494
a
Assume
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.

b
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
September
2004,
"
Table
2.
Civilian
Workers,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
rates
have
been
increased
by
110
percent
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.
Technical
­
$
82.47/
hr;
Managerial
­
$
96.41/
hr;
Clerical
­

$
42.25/
hr
c
Assume
20
percent
of
initial
performance
tests
must
be
repeated
due
to
failure.
G13
TABLE
G.
4:
ANNUAL
BURDEN
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
FOR
SUBPART
DDD
Activity
(
A)

Hours
per
Occurrence
(
B)
Occurrences/

respondent/

year
(
C)
Respondent
s/
year
(
D)
Technical
hr/
yra
(
E=
D*.
05)

Managerial
hr/
yr
(
F=
D*.
10)

Clerical
hr/
yr
(
G)

$
Cost/
yrb
1.
Applications
N/
A
2.
Survey
and
Studies
N/
A
3.
Reporting
Requirements
A.
Read
Instructions
1
1
10
c
10
1
1
$
966
B.
Required
Activities
Initial
Performance
Test
Report
360
1
10
3600
180
360
$
330,428
Repeat
Performance
Test
Report
360
1
2d
720
36
72
$
66,086
C.
Write
Report
Notification
of
Construction/
Modific
ation
2
1
10
20
1
2
$
1,836
Notification
of
Actual
Startup
1
1
10
10
1
1
$
966
Notification
of
Initial
Performance
Test
2
1
10
20
1
2
$
1,836
Semiannual
Report
3
2
90e
540
27
54
$
49,564
Activity
(
A)

Hours
per
Occurrence
(
B)
Occurrences/

respondent/

year
(
C)
Respondent
s/
year
(
D)
Technical
hr/
yra
(
E=
D*.
05)

Managerial
hr/
yr
(
F=
D*.
10)

Clerical
hr/
yr
(
G)

$
Cost/
yrb
G14
Total
Annual
Responses
(
Block
13b)
222
4.
Recordkeeping
Requirements
Record
of
Operating
Parameters
for
Control
Devices
1
12
10
120
6
12
$
11,014
Records
of
Operating
Conditions
Exceeding
Last
Performance
Test
1
8
90
720
36
72
$
66,086
Records
of
Startup,

Shutdown,
Malfunction,
etc.
0.25
5
90
113
6
11
$
10,351
TOTAL
ANNUAL
HOURS
5873
295
587
TOTAL
ANNUAL
BURDEN
6755
$
539,133
a
AxBxC=
D
b
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
September
2004,
"
Table
2.
Civilian
Workers,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
rates
have
been
increased
by
110
percent
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.
Technical
­
$
82.47/
hr;
Managerial
­
$
96.41/
hr;
Clerical
­

$
42.25/
hr
c
Assume
10
new
affected
sources
per
year.
G15
d
Assume
20
percent
of
performance
tests
are
repeated
due
to
failure.

e
Average
number
of
affected
sources
over
next
three
years.
G16
TABLE
G.
5
ANNUAL
BURDEN
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
FOR
SUBPART
III
Activity
(
A)

Hours
per
Occurrence
(
B)
Occurrences/

respondent/

year
(
C)
Respondent
s/
year
(
D)
Technical
hr/
yra
(
E=
D*.
05)

Managerial
hr/
yr
(
F=
D*.
10)

Clerical
hr/
yr
(
G)

$
Cost/
yrb
1.
Applications
N/
A
2.
Survey
and
Studies
N/
A
3.
Reporting
Requirements
0
A.
Read
Instructions
1
1
1
c
1
0
0
$
83
B.
Required
Activities
Initial
Performance
Test
Report
60
1
1
60
3
6
$
5,507
Repeat
Performance
Test
Report
60
1
0.2d
12
1
1
$
1,132
C.
Write
Report
Notification
of
Construction/
Modific
ation
2
1
1
2
0
0
$
165
Notification
of
Actual
Startup
1
1
1
1
0
0
$
83
Notification
of
Initial
Performance
Test
2
1
1
2
0
0
$
165
Semiannual
Report
3
2
11e
66
3
7
$
6,046
Activity
(
A)

Hours
per
Occurrence
(
B)
Occurrences/

respondent/

year
(
C)
Respondent
s/
year
(
D)
Technical
hr/
yra
(
E=
D*.
05)

Managerial
hr/
yr
(
F=
D*.
10)

Clerical
hr/
yr
(
G)

$
Cost/
yrb
G17
Total
Annual
Responses
(
Block
13b)
26
4.
Recordkeeping
Requirements
Record
of
Operating
Parameters
for
Control
Devices
1
12
1
12
1
1
$
1,132
Records
of
Operating
Conditions
Exceeding
Last
Performance
Test
1
8
11
88
4
9
$
8,047
Records
of
Startup,

Shutdown,
Malfunction,
etc.
0.25
5
11
14
1
1
$
1,276
TOTAL
ANNUAL
HOURS
258
13
25
TOTAL
ANNUAL
BURDEN
296
$
23,636
a
AxBxC=
D
b
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
September
2004,
"
Table
2.
Civilian
Workers,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
rates
have
been
increased
by
110
percent
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.
Technical
­
$
82.47/
hr;
Managerial
­
$
96.41/
hr;
Clerical
­

$
42.25/
hr
c
Assume
1
new
affected
source
per
year
subject
to
Subpart
III
and
not
the
HON.
G18
d
Assume
20
percent
of
performance
tests
are
repeated
due
to
failure.

e
Average
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.
G19
TABLE
G.
6
ANNUAL
BURDEN
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
FOR
SUBPART
NNN
Activity
(
A)

Hours
per
Occurrence
(
B)
Occurrences/

respondent/

year
(
C)
Respondent
s/
year
(
D)
Technical
hr/
yra
(
E=
D*.
05)

Managerial
hr/
yr
(
F=
D*.
10)

Clerical
hr/
yr
(
G)

$
Cost/
yrb
1.
Applications
N/
A
2.
Survey
and
Studies
N/
A
3.
Reporting
Requirements
A.
Read
Instructions
1
1
177c
177
9
18
$
16,273
B.
Required
Activities
Initial
Performance
Test
Report
60
1
177
10,620
531
1,062
$
974,762
Repeat
Performance
Test
Report
60
1
35d
2,100
105
210
$
192,750
C.
Write
Report
Notification
of
Construction/
Modific
ation
2
1
177
354
18
35
$
32,504
Notification
of
Actual
Startup
1
1
177
177
9
18
$
16,273
Notification
of
Initial
Performance
Test
2
1
177
354
18
35
$
32,504
Semiannual
Report
3
2
1345e
8,070
404
807
$
740,757
Activity
(
A)

Hours
per
Occurrence
(
B)
Occurrences/

respondent/

year
(
C)
Respondent
s/
year
(
D)
Technical
hr/
yra
(
E=
D*.
05)

Managerial
hr/
yr
(
F=
D*.
10)

Clerical
hr/
yr
(
G)

$
Cost/
yrb
G20
Total
Annual
Responses
(
Block
13b)
3,433
4.
Recordkeeping
Requirements
Record
of
Operating
Parameters
for
Control
Devices
1
12
177
2,124
106
212
$
194,916
Records
of
Operating
Conditions
Exceeding
Last
Performance
Test
1
8
1345
10,760
538
1,076
$
987,612
Records
of
Startup,

Shutdown,
Malfunction,
etc.
0.25
5
1345
1,681
84
168
$
154,303
TOTAL
ANNUAL
HOURS
36,417
1,822
3,641
TOTAL
ANNUAL
BURDEN
41,880
$
3,342,654
a
AxBxC=
D
b
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
September
2004,
"
Table
2.
Civilian
Workers,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
rates
have
been
increased
by
110
percent
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.
Technical
­
$
82.47/
hr;
Managerial
­
$
96.41/
hr;
Clerical
­

$
42.25/
hr
G21
c
Assume
177
new
affected
sources
per
year
subject
to
Subpart
NNN
and
not
the
HON.

d
Assume
20
percent
of
performance
tests
are
repeated
due
to
failure.

e
Average
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.
G22
TABLE
G.
7
ANNUAL
BURDEN
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
FOR
SUBPART
RRR
Activity
(
A)

Hours
per
Occurrence
(
B)
Occurrences/

respondent/

year
(
C)
Respondents/

year
(
D)
Technical
hr/
yra
(
E=
D*.
05)
Managerial
hr/
yr
(
F=
D*.
10)

Clerical
hr/
yr
(
G)

$
Cost/
yrb
1.
Applications
N/
A
2.
Survey
and
Studies
N/
A
3.
Reporting
Requirements
A.
Read
Instructions
1
1
20
c
20
1
2
$
1,836
B.
Required
Activities
Initial
Performance
Test
Report
60
1
20
1,200
60
120
$
110,143
Repeat
Performance
Test
Report
60
1
4d
240
12
24
$
22,029
C.
Write
Report
Notification
of
Construction/

Modification
2
1
20
40
2
4
$
3,671
Notification
of
Actual
Startup
1
1
20
20
1
2
$
1,836
Notification
of
Initial
Performance
Test
2
1
20
40
2
4
$
3,671
Semiannual
Report
3
2
155e
930
47
93
$
85,409
Activity
(
A)

Hours
per
Occurrence
(
B)
Occurrences/

respondent/

year
(
C)
Respondents/

year
(
D)
Technical
hr/
yra
(
E=
D*.
05)
Managerial
hr/
yr
(
F=
D*.
10)

Clerical
hr/
yr
(
G)

$
Cost/
yrb
G23
Total
Annual
Responses
(
Block
13b)
394
4.
Recordkeeping
Requirements
Record
of
Operating
Parameters
for
Control
Devices
1
12
20
240
12
24
$
22,029
Records
of
Operating
Conditions
Exceeding
Last
Performance
Test
1
8
155
1,240
62
124
$
113,814
Records
of
Startup,

Shutdown,
Malfunction,
etc.
0.25
5
155
194
10
19
$
17,798
TOTAL
ANNUAL
HOURS
4,164
209
416
TOTAL
ANNUAL
BURDEN
4,789
$
382,236
a
AxBxC=
D
b
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
September
2004,
"
Table
2.
Civilian
Workers,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
rates
have
been
increased
by
110
percent
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.
Technical
­
$
82.47/
hr;
Managerial
­
$
96.41/
hr;
Clerical
­

$
42.25/
hr.

c
Assume
20
new
affected
sources
per
year
subject
to
Subpart
RRR
and
not
the
HON.
G24
d
Assume
20
percent
of
performance
tests
are
repeated
due
to
failure.
(.
2
x
20
=
4)

e
Average
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.
G25
TABLE
G.
8
ANNUAL
BURDEN
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
FOR
SUBPART
BB
(
A)

hr/
Occurrence
(
B)
Occurrences/

Respondent/
yr
(
C)
a
Respondent/

yr
(
D)
Technical
hr/
yr
(
E=
D*.
05)
Managerial
hr/
yr
(
F=
D*.
10)

Clerical
hr/
yr
(
G)

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
0
0
0
0
$
0
B.
Required
Activities
Initial
emission
test
20
0
0
0
0
0
$
0
Monitoring
performance
test
280
1
0
0
0
0
$
0
Vapor­
tightness
test
tank
truck
and
railcars
11
1
3c
33
2
3
$
3,050
Marine
vessels
80
1
66c
5,280
264
528
$
484,627
Closed
vent
leak
inspection
8
1
54
c
432
22
43
$
39,681
C.
Create
Information
Included
in
3B
(
A)

hr/
Occurrence
(
B)
Occurrences/

Respondent/
yr
(
C)
a
Respondent/

yr
(
D)
Technical
hr/
yr
(
E=
D*.
05)
Managerial
hr/
yr
(
F=
D*.
10)

Clerical
hr/
yr
(
G)

Cost/
yrb
G26
D.
Gather
Existing
Information
Included
in
3E
E.
Write
Report
Notification
of
anticipated
startup
2
0
0
0
0
0
$
0
Notification
of
actual
startup
2
0
0
0
0
0
$
0
Notification
of
emission
test
2
0
0
0
0
0
$
0
Report
of
emission
test
8
0
0
0
0
0
$
0
Notification
of
performance
test
2
0
0
0
0
0
$
0
Report
of
performance
test
8
0
0
0
0
0
$
0
Report
facilities
below
cut­
offd
8
0
0
0
0
0
$
0
Quarterly
parameter
excesses
4
4
54
864
43
86
$
79,266
Total
Annual
Responses
(
Block
13b)
216
(
A)

hr/
Occurrence
(
B)
Occurrences/

Respondent/
yr
(
C)
a
Respondent/

yr
(
D)
Technical
hr/
yr
(
E=
D*.
05)
Managerial
hr/
yr
(
F=
D*.
10)

Clerical
hr/
yr
(
G)

Cost/
yrb
G27
SUBTOTAL
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
i.
Facilities
above
cutoff
1.5
52
54
4,212
211
421
$
386,631
ii.
Facilities
below
cutoffd
0.5
52
0
0
0
0
$
0
F.
Train
Personnel
N/
A
G.
Audits
N/
A
TOTAL
ANNUAL
HOURS
10,821
542
1,081
(
A)

hr/
Occurrence
(
B)
Occurrences/

Respondent/
yr
(
C)
a
Respondent/

yr
(
D)
Technical
hr/
yr
(
E=
D*.
05)
Managerial
hr/
yr
(
F=
D*.
10)

Clerical
hr/
yr
(
G)

Cost/
yrb
G28
TOTAL
ANNUAL
BURDEN
12,444
$
993,255
a
Expect
that
there
will
be
no
new
sources
covered
by
these
standards
over
the
next
three
years.

b
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
September
2004,
"
Table
2.
Civilian
Workers,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
rates
have
been
increased
by
110
percent
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.
Technical
­
$
82.47/
hr;
Managerial
­
$
96.41/
hr;
Clerical
­

$
42.25/
hr.

c
Estimate
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
percent
of
the
marine
vessels
(
66)
operate
at
negative
pressure
and
do
not
conduct
annual
vapor­
tightness
tests.

d
For
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.
G29
TABLE
G.
9
ANNUAL
BURDEN
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
FOR
SUBPART
Y
(
A)

hr/
Occurrence
(
B)
Occurrences/

Respondent/
yr
(
C)
a
Respondent/

yr
(
D)
Technical
hr/
yr
(
E=
D*.
05)
Managerial
hr/
yr
(
F=
D*.
10)

Clerical
hr/
yr
(
G)

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
Annual
IFR
Internal
Inspections
and
EFR
Seal
Gap
measurements
(
existing
sources)
8
1
4
32
2
3
$
2,967
D.
Gather
Existing
Information
Included
in
3C
E.
Write
Report
New
Sources
(
A)

hr/
Occurrence
(
B)
Occurrences/

Respondent/
yr
(
C)
a
Respondent/

yr
(
D)
Technical
hr/
yr
(
E=
D*.
05)
Managerial
hr/
yr
(
F=
D*.
10)

Clerical
hr/
yr
(
G)

Cost/
yrb
G30
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
N/
A
Report
of
emission
test
N/
A
Notification
of
Control
installation
and
refill
at
1st
IFR
Degassingc
2
1
0
0
0
0
$
0
Existing
Sources
Annual
Inspection
Reports
2
2
4
16
1
2
$
1,505
Supplemental
Delay
Reportd
2
1
0
0
0
0
$
0
Quarterly
Emission
Report
None
Expectede
Total
Annual
Responses
(
Block
13b)
8
4.
Recordkeeping
Requirements
(
A)

hr/
Occurrence
(
B)
Occurrences/

Respondent/
yr
(
C)
a
Respondent/

yr
(
D)
Technical
hr/
yr
(
E=
D*.
05)
Managerial
hr/
yr
(
F=
D*.
10)

Clerical
hr/
yr
(
G)

Cost/
yrb
G31
A.
Read
Instructions
Included
in
3A
B.
Plan
Activities
Included
in
4C
C.
Implement
Activities
­

Filing
and
Maintaining
Records
2
1
4
8
0
1
$
704
D.
Develop
Record
System
Included
in
4C
E.
Time
to
Enter
Information
Included
in
4C
F.
Train
Personnel
N/
A
G.
Audits
N/
A
TOTAL
ANNUAL
HOURS
56
3
6
TOTAL
ANNUAL
BURDEN
65
$
5,176
a
Estimate
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
b
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
September
2004,
"
Table
2.
Civilian
Workers,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
rates
have
been
increased
by
110
percent
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.
Technical
­
$
82.47/
hr;
Managerial
­
$
96.41/
hr;
Clerical
­

$
42.25/
hr
c
It
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.

d
Estimate
that
two
percent
of
existing
sources
will
request
delay
of
repair
in
the
annual
report.
G32
e
Assume
that
no
sources
will
select
the
fixed
roof
vented
to
a
control
device
option
and
thus
have
no
quarterly
reports
of
excess
emissions.
TABLE
G.
10
ANNUAL
BURDEN
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
FOR
SUBPART
V
Activity
(
A)
Hours/
Occurrence
(
B)
Occurrences/

respondent/

year
(
C)
Respondents/

year
(
D)
Technical
hr/
yr
(
E=
D*.
05)
Managerial
hr/
yr
(
F=
D*.
10)

Clerical
hr/
yr
(
G)
a
Cost/
year
1.
Applications
N/
A
2.
Survey
and
Studies
N/
A
3.
Reporting
Requirements
A.
Read
Instructions
1
1
2
b
2
0
0
$
165
B.
Required
Activities
Initial
Performance
Test
20
1
2
40
2
4
$
3,671
Reference
Method
21/
22
Tests
4
1
2
8
0
1
$
704
Repeat
Performance
Test
20
0.2
2
8
0
1
$
704
C.
Create
Information
See
3B
D.
Gather
Existing
Information
See
3B
Activity
(
A)
Hours/
Occurrence
(
B)
Occurrences/

respondent/

year
(
C)
Respondents/

year
(
D)
Technical
hr/
yr
(
E=
D*.
05)
Managerial
hr/
yr
(
F=
D*.
10)

Clerical
hr/
yr
(
G)
a
Cost/
year
G33
E.
Write
Report
Notification
of
Construction/
Reconstruction
2
1
2
4
0
0
$
331
Notification
of
Anticipated
Startup
2
1
2
4
0
0
$
331
Notification
of
Actual
Startup
2
1
2
4
0
0
$
331
Notification
of
Initial
Performance
Test
2
1
2
4
0
0
$
331
Report
of
Performance
Test
See
3B
Application
for
Alternative
10
1
0.5
5
0
1
$
456
Initial
Report
8
1
2
16
1
2
$
1,505
Semiannual
Report
30
2
55c
3,300
165
330
$
302,892
Total
Annual
Responses
(
Block
13b)
123
4.
Recordkeeping
Requirements
A.
Read
Instructions
See
3A
B.
Plan
Activities
See
4C
Activity
(
A)
Hours/
Occurrence
(
B)
Occurrences/

respondent/

year
(
C)
Respondents/

year
(
D)
Technical
hr/
yr
(
E=
D*.
05)
Managerial
hr/
yr
(
F=
D*.
10)

Clerical
hr/
yr
(
G)
a
Cost/
year
G34
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
2
3
0
0
$
248
Records
of
operating,

parameters
and
emissions
0.1
365d
55c
2,008
100
201
$
184,234
Records
of
leak
detected
0.4
52
55
1,144
57
114
$
104,966
F.
Train
personnel
N/
A
G.
Audits
N/
A
TOTAL
ANNUAL
HOURS
6,550
325
654
TOTAL
ANNUAL
BURDEN
7,529
$
600,869
a
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
September
2004,
"
Table
2.
Civilian
Workers,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
rates
have
been
increased
by
110
percent
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.
Technical
­
$
82.47/
hr;
Managerial
­
$
96.41/
hr;
Clerical
­

$
42.25/
hr
b
Assume
one
new
facility
per
year
comprising
two
new
sources.

c
Estimate
21
existing
facilities
comprising
55
sources.
G35
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
per
year
(
h)

1)
Read
Rule
and
Instructions
2.7
93
250
5
1,250
63
125
$
114,780
2)
Plan
Activities
3.8
93
355
5
1,775
89
178
$
162,964
3)
Training
3.5
38
132
5
660
33
66
$
60,578
4)
Create,
Test,

Research
and
Development
2.4
1,778
4,266
5
21,330
1,067
2,133
$
1,957,833
5)
Gather
Information,

Monitor/
Inspect
1.4
2,102
2,943
5
14,715
736
1,472
$
1,350,669
6)
Process/
Compile
and
Review
0.8
50
40
5
200
10
20
$
18,357
7)
Complete
Reports
11.4
49
557
5
2,785
139
279
$
255,620
Total
Annual
Responses
(
Block
13b)
245
8)
Record/
Disclose
10.0
49
489
5
2,445
122
245
$
224,413
9)
Store/
File
5.2
51
264
5
1,320
66
132
$
121,157
TOTAL
ANNUAL
HOURS
46,480
2,325
4,650
TOTAL
ANNUAL
BURDEN
53,455
$
4,266,371
(
a)
=
(
c)/(
b)

(
d)
­
From
previously
approved
ICR.

See
Attachment
I
for
assumptions
and
further
description
of
activities.
G36
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
(
d)
Estimated
Technical
Hours
per
year
(
e)
Estimated
Managerial
Hours
per
year
(
f)
Estimated
Clerical
Hours
per
year
(
g)
Annual
Cost
$
per
year
(
h)

1)
Read
Rule
and
Instructions
3.6
23
69
14
17,680
884
1,768
$
1,097,548
2)
Plan
Activities
6.1
13
61
18
16,080
804
1,608
$
998,222
3)
Training
5.3
4
17
4
4,400
220
440
$
273,145
4)
Create,
Test,

Research
and
Development
17.8
99
1617
150
400,080
20,004
40,008
$
24,836,366
5)
Gather
Information,

Monitor/
Inspect
2.5
677
1693
0
406,320
20,316
40,632
$
25,223,736
6)
Process/
Compile
and
Review
20.0
1
20
0
4,800
240
480
$
297,977
7)
Complete
Reports
81.2
5
388
18
94,560
4,728
9,456
$
5,870,143
Total
Annual
Responses
(
Block
13b)
a
1,600
8)
Record/
Disclose
17.5
26
442
12
107,040
5,352
10,704
$
6,644,883
9)
Store/
File
6.8
35
222
15
54,480
2,724
5,448
$
3,382,037
TOTAL
ANNUAL
HOURS
1,105,440
55,272
110,544
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
(
d)
Estimated
Technical
Hours
per
year
(
e)
Estimated
Managerial
Hours
per
year
(
f)
Estimated
Clerical
Hours
per
year
(
g)
Annual
Cost
$
per
year
(
h)

G37
TOTAL
ANNUAL
BURDEN
1,271,256
$
68,624,057
(
a)
=
(
c
+
d)/(
b)

(
c)
­
there
are
240
existing
sources
out
of
the
320
total
that
will
continue
to
comply
with
the
HON.

(
d)
­
the
80
facilities
complying
with
the
CAR
will
still
be
required
to
comply
with
the
HON
for
wastewater.

a
Total
number
of
respondents
is
320
(
240
for
HON
+
80
CAR
still
complying
with
HON
Wastewater).

See
Attachment
I
for
assumptions
and
further
description
of
activities.
H1
Attachment
H
Assumptions
and
Item
Descriptions
for
Attachment
F:
Table
F.
11
(
A)
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.
(
B)
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).

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
one­
time
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
percent
of
(
c).
(
e)
Estimated
Clerical
Hours
per
year
is
10
percent
of
(
c).
(
f)
Estimated
Annual
Cost
per
year
is
the
sum
of
costs
for
technical,
managerial,
and
clerical
hours
based
on
rates
from
the
Office
of
Personnel
Management
(
OPM)
"
2004
General
Schedule"
which
excludes
locality
rates
of
pay.
Technical
­
$
41.57
(
GS­
12,
Step
1,
$
25.98
x
1.6)
Managerial
­
$
56.02
(
GS­
13,
Step
5,
$
35.01
x
1.6)
Clerical
$
22.50
(
GS­
6,
Step
3,
$
14.06
x
1.6)

(
Ht
x
$
41.57/
hour)+(
Hm
x
$
56.02/
hour)+(
Hc
x
$
14.06/
hour)
=
(
G)

Where:
Ht
is
(
c),
or
technical
hours
Hm
is
(
d),
or
managerial
hours,
and
Hc
is
(
e),
clerical
hours
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
H2
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
(
d),
(
e),
(
f)
and
(
g).
I1
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
percent
(.
05)
managerial
and
10
percent
(.
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
back­
calculate
(
a).
(
c)
Technical
Hours
per
year
per
source
is
the
actual
best
estimate
of
the
burden
for
each
burden
item.
The
three­
year
separate
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
I2
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
percent
of
(
e).
(
g)
Estimated
Clerical
Hours
per
year
is
10
percent
of
(
e).
(
h)
Estimated
Annual
Cost
per
year
is
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
September
2004,
"
Table
2.
Civilian
Workers,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
rates
have
been
increased
by
110
percent
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.

(
Ht
x
$
82.74/
hour)+(
Hm
x
$
96.41/
hour)+(
Hc
x
$
42.25/
hour)
=
(
G)

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
percent)
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
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
I3
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).
J1
Attachment
J
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
Monitoring
Equipment:
The
total
Capital/
Start­
up
costs
for
this
ICR
are
$
0.

b.
Total
Cost
of
Operation
and
Maintenance
of
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
Monitoring
Equipment:
The
total
Capital/
Start­
up
costs
for
this
ICR
are
$
27,000.
This
is
the
cost
for
2
new
storage
tanks
to
install
monitoring
equipment
associated
with
the
CVS
routed
to
a
control
device.
The
storage
tanks
will
use
equipment
similar
to
that
used
for
subparts
NNN
and
III;
therefore
the
startup
costs
is
approximately
$
13,500
per
facility
for
a
total
of
$
27,000.
There
are
no
capital/
startup
costs
for
the
remaining
35
new
storage
tanks
complying
by
either
an
IFR
or
EFR.

b.
Total
Cost
of
Operation
and
Maintenance
of
Monitoring
Equipment:
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
both
new
and
existing
affected
sources
using
CVS
to
a
control
device
(
31)
for
a
total
of
$
41,850
.

c.
Total
Capital/
Startup
and
O&
M
Cost:
The
total
Capital
and
O&
M
Costs
are
$
68,850.

NSPS
Subpart
VV
a.
Total
Capital/
Startup
Cost
of
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
percent
of
facilities
contract
out
LDAR
services
and
20
percent
perform
in­
house.
Those
facilities
which
contract
J2
out
will
purchase
one
unit
as
backup;
the
remaining
facilities
performing
LDAR
inhouse
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
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:
The
total
Capital
and
O&
M
Costs
are
$
35,000.

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

b.
Total
Cost
of
Operation
and
Maintenance
of
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.

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
Monitoring
Equipment:
The
startup
cost
of
monitoring
equipment
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
Monitoring
Equipment:
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].

c.
Total
Capital/
Startup
and
O&
M
Cost:
J3
The
total
Capital
and
O&
M
Costs
are
$
4,233,600.

NSPS
Subpart
RRR
a.
Total
Capital/
Startup
cost
of
Monitoring
Equipment:
The
capital/
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
monitoring
equipment
discounted
over
10
years
at
7
percent.

b.
Total
Cost
of
Operation
and
Maintenance
of
Monitoring
Equipment:
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/
startup
and
O&
M
Costs
are
$
577,500.

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

b.
Total
Cost
of
Operation
and
Maintenance
of
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
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
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
Monitoring
Equipment:
Startup
cost
were
identified
in
previous
ICR.
J4
b.
Total
Cost
of
Operation
and
Maintenance
of
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:

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

b.
Total
Cost
of
Operation
and
Maintenance
of
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.

c.
Total
Capital/
Startup
and
O&
M
Cost:
The
total
Capital
and
O&
M
Costs
are
$
67,500,000.

Subpart
H
a.
Total
Capital/
Startup
Cost
of
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
percent
of
facilities
contract
out
LDAR
services
and
20
percent
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.
J5
b.
Total
Cost
of
Operation
and
Maintenance
of
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
H,
and
I:
The
total
Capital
and
O&
M
Costs
are
$
12,600.

Part
65
CAR
a.
Total
Capital/
Startup
Cost
of
Monitoring
Equipment:
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
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.
