SF-83 SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NSPS for Equipment Leaks of VOC in Petroleum Refineries

(40 CFR Part 60, Subpart GGG)

1.  Identification of the Information Collection

	1(a)  Title of the Information Collection

	NSPS for Equipment Leaks of VOC in Petroleum Refineries (40 CFR part
60, subpart GGG)

	1(b)  Short Characterization/Abstract

	The New Source Performance Standards (NSPS) for Equipment Leaks of VOC
(Volatile Organic Compound) in Petroleum Refineries were proposed on
January 4, 1983, and promulgated on May 30, 1984.  These standards apply
to the following facilities in petroleum refineries: compressors and the
group of all equipment (e.g., valves, pumps, flanges, etc.) within a
process unit in VOC service, commencing construction, modification or
reconstruction after the date of proposal.  This information is being
collected to assure compliance with 40 CFR part 60, subpart GGG.

	Owners or operators of the affected facilities described must make the
following one-time only reports: notification of the date of
construction or reconstruction; notification of the actual date of
startup; notification of any physical or operational change to an
existing facility which may increase the regulated pollutant emission
rate; notification of the date of the initial performance test; and the
results of the initial performance test.  Owners or operators are also
required to maintain records of the occurrence and duration of any
startup, shutdown, or malfunction in the operation of an affected
facility, or any period during which the monitoring system is
inoperative.  Monitoring requirements specific to Equipment Leaks of VOC
in Petroleum Refineries provide information regarding which components
are leaking VOCs.  NSPS subpart GGG references the compliance
requirements of NSPS subpart VV.  On a periodic basis, which varies
depending on equipment type and leak history, owners or operators are
required to record: 1) information identifying leaking equipment and 2)
repair methods used to stop the leaks, and 3) dates of repair. 
Semiannual reports are required to measure compliance with the standards
of NSPS subpart VV as referenced by NSPS subpart GGG.  In general, these
notifications, reports and records are required of all sources subject
to NSPS.

	Any owner or operator subject to the provisions of this part will
maintain a file of these records, and retain the file for at least two
years following the date of such records.  All reports are sent to the
delegated state or local authority.  In the event that there is no such
delegated authority, the reports are sent directly to the EPA regional
office.

	In the development of this Information Collection Request (ICR), we
reviewed the Office of Management and Budget (OMB) “Terms of
Clearance” (TOC) section on the active ICR.  There were no comments in
the TOC section.

	We have determined that there are approximately 148 petroleum refiners
would have at least one process unit (affected facility) subject to the
monitoring, recordkeeping and reporting requirements of NSPS subpart
GGG/VV.  Due to consolidation of several industry refiners, we have
further assumed that no new sources are expected to become subject to
the standard over the next three years.  These assumptions were made
based on information available on EPA’s database system and
consultation with the industry sector leads at the Office of Air Quality
Planning and Standards (OAQPS) and the National Petroleum Refiners
Association.  This research resulted in a significantly higher number of
sources (100 more sources) being accounted for in the burden calculation
for the renewal of this ICR and, therefore, reflects a more accurate
estimate.

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

	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 (70 FR 24020) on May 6, 2005.  No
comments were received on the burden published in the Federal Register.

	3(c)  Consultations

	We have reviewed our internal data sources and discussed the industry
growth rate with the rule contacts for this industry category at the
EPA’s Office of Air Quality Planning and Standards (OAQPS) and Norbert
Dee of the National Petrochemical and Refiners Association in
Washington, D.C., at (202) 457-0480.  In addition, the Agency has
initiated additional reviews on the sector to evaluate any residual risk
from this regulation and determine if there is a need to change any of
the monitoring, recordkeeping and reporting requirements of this rule.

	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.  This NSPS standard requires respondents
to maintain all records, including reports and notifications, for two
years.  Less frequent information collection would decrease the margin
of assurance that facilities are continuing to meet the required
standards.  Requirements for information gathering and recordkeeping are
useful techniques to ensure that good operation and maintenance
practices are applied and emission limitations are met.  If the
information required by these standards was collected less frequently,
the likelihood of detecting poor operation and maintenance of control
equipment and noncompliance would decrease.

	3(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.

	Regulation		SIC Codes		NAICS Codes

NSPS for Equipment Leaks of VOC in Petroleum Refineries (40 CFR Part 60,
subpart GGG)	SIC 2911 	NAIC 324110



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, review the applicability provisions in the standard.

	4(b)  Information Requested

		(i)  Data Items

	

	All data in this ICR that is recorded and/or reported is required by 40
CFR part 60, subpart XX Bulk Gasoline Terminals.

	A source must make the following reports:

Notification Reports

Notification of construction or reconstruction	40 CFR 60.7(a)(1)

Notification of anticipated date of initial startup	40 CFR 60.7(a)(2)

Notification of actual date of initial startup	40 CFR 60.7(a)(3)

Notification of physical or operational change		40 CFR 60.7(a)(4)

Maintain records of startups, shutdowns or malfunctions.	40 CFR 60.7(b)

Notification of performance test.	40 CFR 60.8(d)



Reports

Report of performance tests	40 CFR 60.8(a), 

40 CFR 487(e)

Comply with the provisions of NSPS subpart VV at 40 CFR 60.487	40 CFR
60.592(e)

Semiannual reports	40 CFR 60.486, 40 CFR 60.487(a-c)



		A source must maintain the following records:

Recordkeeping 

Startups, shutdowns, malfunctions	60.7(b)

All measurements, monitoring device, and performance testing
measurements	60.7(e)

Comply with the provisions of 60.486	60.592(e)

Each detected leak shall be recorded in a log and kept for 2 years
60.486(c)

Information pertaining to design requirements or closed vent systems and
control devices	60.486(d)

Information pertaining to all equipment	60.486(e)

Information pertaining to all valves	60.486(f)

Information pertaining to valves complying with alternative compliance
requirements	60.486(g)

Design criteria and any changes	60.486(h)

Records for use in determining exemptions	60.486(i)

Information and data to demonstrate that a piece of equipment is not in
VOC service	60.486(j)



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 10 percent of the respondents use
electronic reporting.

		(ii)  Respondent Activities	

Respondent Activities

Read instructions

Perform initial performance test as per 40 CFR 60.485, Reference Method
21 and 22 tests, and repeat performance tests

Write the notifications and reports listed above

Enter information required to be recorded above

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

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

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

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

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

Transmit or otherwise disclose the information



	As refiners replace/upgrade their monitoring equipment, they may choose
to use systems that automatically log the results of monitoring, which
can then be downloaded into a computer database.  This database can then
be used to develop and submit the required reports electronically.

5.  The Information Collected: Agency Activities, Collection
Methodology, and Information Management

	5(a)  Agency Activities 

EPA conducts the following activities in connection with the
acquisition, analysis, storage, and distribution of the information
required under NSPS subpart GGG:

	Agency Activities

Observe initial performance tests and repeat performance tests if
necessary

Review notifications and reports, including performance test reports,
and other reports, required to be submitted by industry

Audit facility records

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



	5(b)  Collection Methodology and Management

	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 headquarters and EPA regional offices. EPA and delegated
authorities can retrieve and analyze the data.

	5(c)  Small Entity Flexibility

	A majority of the affected facilities by this regulation are large
businesses.  However, the impact on small businesses was taken into
consideration during development of the regulation.  Due to technical
considerations involving the process operations and leak detection and
repair programs, the recordkeeping and reporting requirements are the
same for both small and large businesses.  However, for sources that
install “leakless” components, monitoring may not be required for
those components.  Therefore, the monitoring and recordkeeping may also
be reduced for sources that maintain low percentages of leaking
components.  Additionally, alternative means of emission limitation are
allowed after proper demonstration of their effectiveness to the
Administrator.

	The Agency considers these requirements to be the minimum needed to
ensure compliance and, therefore, cannot reduce them further for small
businesses.  To the extent that larger businesses can use economies of
scale to reduce their burden, the overall burden will be reduced.

	5(d)  Collection Schedule

	The specific frequency for each information collection activity within
this request is shown in Table 1, attached.

6.  Estimating the Burden and Cost of the Collection

	Table 1 documents the computation of individual burdens for the
recordkeeping and reporting requirements applicable to the industry. 
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 average annual burden to industry over the next three years from
these recordkeeping and reporting requirements is estimated at 21,360
person-hours, as shown in Table 1, attached.  The labor hours in Table 1
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	$97.46   ($46.41 + 110%)

		Technical	$83.71   ($39.86 + 110%)

		Clerical	$42.55   ($20.26 + 110%)

These rates are from the United States Department of Labor, Bureau of
Labor Statistics, March 19, 2005, “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

	The only type of industry costs associated with the information
collection activity in the standards are labor costs.  There are no
capital/startup and operation and maintenance costs associated with the
leak detection and repair requirements for this rule.  Costs associated
with equipment for VOC leaks cannot be attributed to this rule since
these are used by industry as part of their normal operations for safety
reasons and do not involve the use of continuous monitors.

		(iii)  Capital/Startup vs. Operation and Maintenance (O&M) Costs

	The average annual costs for capital/startup and operation and
maintenance costs to industry over the next three years of the ICR is
zero because no continuous monitoring equipment is required under the
leak detection and repair program of this regulation.  This is shown on
the OMB 83-I form in Section 14 as follows: block 4(a), Total annualized
capital/startup costs; block 14(b), Total annual costs (O&M); 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 cost during the three years of the ICR is
estimated to be $55,199, as shown in Table 2, attached.

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

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

		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) “2005
General Schedule” which excludes locality rates of pay.

	6(d)  Estimating the Respondent Universe and Total Burden and Costs

	Number of respondents is calculated using the following table which
addresses the three years covered by this ICR.

Number of Respondents

	Respondents That Submit Reports	Respondents That Do Not Submit Any
Reports

	Year	(A)

Number of New Respondents	(B)

Number of Existing Respondents	(C)

Number of Existing Respondents That Keep Records but Do Not Submit
Reports	(D)

Number of Existing Respondents That Are Also New Respondents	(E)

Number of Respondents

(E=A+B+C-D)

1	0	148	0	0	148

2	0	148	0	0	148

3	0	148	0	0	148

Average	0	148	0	0	148

	1 New respondents would typically include sources with constructed,
reconstructed and modified affected facilities.  However, for this
industry category a new source would be required to comply with more
recent equipment leaks standards and not this standard.

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

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

Total Annual Responses

(A)

Information Collection Activity	(B)

Number of Respondents	(C)

Number of Responses	(D)

Number of Existing Respondents That Keep Records But Do Not Submit
Reports	(E)

Total Annual Responses 

E=(BxC)+D

Semiannual Reports	148	2	0	296

Initial Notifications 	0	4	0	0

Report of Performance Report	0	1	0	0

Total



296



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

	The Total Hours Requested is shown on the OMB 83-I form in block 13(c).
 The total annual labor cost may be found in Table 1.

	The average annual Agency burden and cost over next three years is
shown in Table 2.

	6(e)  Bottom Line Burden Hours and Cost Tables

	The detailed bottom line burden hours and cost calculations for the
respondents and the Agency are shown in Tables 1 and 2, respectively.

		(i) Respondent Tally

	The Total Hours Requested is shown on the OMB 83-I form in block 13(c).
 The annual labor costs are not shown on the OMB 83-I form.  Details
regarding these estimates may be found in Table 1.  Furthermore, the
annual public reporting and recordkeeping burden for this collection of
information is estimated to average 72 hours (rounded) 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 shown in Table 2.

	6(f)  Reasons for Change in Burden

	The increase in labor burden to industry from the most recently
approved ICR from 6,137 to 21,360 is due to an adjustment.  The burden
change resulted from an increase from 48 to 148 on the number of sources
subject to the standard which is based on recent Agency data available
on the sector and consultation with industry, as discussed in Section 3
of this report.  We also removed any burden associated with new sources
complying with the initial rule requirements due to the assumption that
there will be no industry growth.  The total industry cost also
increased from $631,983 to $1,724,344 as a result of these changes, and
the use of an updated technical labor rate and the addition of the
Management and Clerical labor hours associated with the standards.

	There were no capital/startup and operation and maintenance costs
associated with continuous emission monitoring for the renewal of the
ICR, therefore, there is no change in this burden category.  This is
based on the fact that this regulation does not require the use of
continuous emission monitoring systems.

	The Agency burden increase is due to the review of semiannual reports
for more number of sources, as discussed above, and the use of updated
higher labor rates which did not offset the decrease in burden
associated with new sources submitting initial reports.

	6(g)  Burden Statement

	The annual public reporting and recordkeeping burden for this
collection of information is estimated to average 72 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.

	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-2005-0018, which is available for public viewing at the Enforcement
and Compliance Docket and Information Center in the EPA Docket Center
(EPA/DC), EPA West, Room B102, 1301 Constitution Avenue, NW, Washington,
D.C.  The EPA Docket Center Public Reading Room is open from 8:30 a.m.
to 4:30 p.m., Monday through Friday, excluding legal holidays.  The
telephone number for the Reading Room is (202) 566-1744, and the
telephone number for the Enforcement and Compliance Docket and
Information Center 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, D.C. 20503,
Attention: Desk Officer for EPA.  Please include the EPA Docket ID
Number OECA-2005-0018 and OMB Control Number 2060-0067 in any
correspondence.

Part B of the Supporting Statement

	This part is not applicable because no statistical methods were used in
collecting this information.

Table 1.  Annual Respondent Burden and Cost:  NSPS for Equipment Leaks
of VOC in Petroleum Refineries

(40 CFR Part 60, Subpart GGG)

Burden item	

(A)

Person-

hours per

occurrence	

(B)

No.  of

occurrences

per respondent

per year	

(C)

Person-

hours per

respondent

per year

(C=AxB)	

(D)

Respondents

per year  a	

(E)

Technical

person-

hours per

year

(E=CxD)	

(F)

Management

person-hours

per year

(Ex0.05)	

(G)

Clerical

person-

hours per 	year

(Ex0.1)	

(H)

Cost, $  b



1.  Applications	

N/A	

	

	

	

	

	

	





2.  Survey and Studies	

N/A	

	

	

	

	

	

	





3.  Acquisition, Installation,         and Utilization of  Technology
and  Systems	

N/A	

	

	

	

	

	

	





4.  Reporting Requirements	

	

	

	

	

	

	

	





  A.  Read instructions	

1	

1	

1	

0	

0.0	

0.0	

0.0	

$0.00



  B.  Required activities:	

	

	

	

	

	

	

	





   i.  Initial Performance tests  c    	

24	

1	

24	

0	

0.0	

0.0	

0.0	

$0.00



   ii.  Repeat Performance tests  c    	

24	

0.2	

4.8	

0	

0.0	

0.0	

0.0	

$0.00

  

   iii.  Monitoring of operations          and equipment:  d











D.  Gather Existing Information	

Included in 4B and 5E	

	

	

	

	

	





E.  Write report   a, c 	

	

	

	

	

	

	

	





 

   i.  Notification of actual                 startup	

2	

1	

2	

0	

0.0	

0.0	

0.0	

$0.00



   ii.  Notification of                          construction/
modification   a	

2	

1	

2	

0	

0.0	

0.0	

0.0	

$0.00



   iii.  Notification of                         Performance Test 	

2	

1	

2	

0	

0.0	

0.0	

0.0	

$0.00



   iv.  Reports of performance           test results	

Included in  4B









   v.  Semi-annual reports   e      	

8	

2	

16	

148	

2,368.0	

118.4	

236.8	

$219,840.38



5.  Recordkeeping Requirements	

	

	

	

	

	

	

	





 A.  Read instructions	

Included in 4A	

	

	

	

	

	





 B.  Plan activities	

Included in 4B	

	

	

	

	

	



 

C.  Implement activities	

Included in 4B	

	

	

	

	

	





D.  Develop record system	

N/A









E.  Time to enter and transmit    information:  Monitoring of operations
include leak detection records   f	

0.3	

365	

109.5	

148	

16,206.0	

810.3	

1,620.6	

$1,504,503.39



F.  Time to train personnel	

N/A	

	

	

	

	

	

	





G. Time for audits	

N/A	

	

	











TOTAL LABOR  BURDEN AND COST  	

	

	

	

	

18,574.0	

928.7	

1,857.4	

$1,724,343.77



TOTAL LABOR HOURS (Rounded)	

	

	

	

	

21,360	

$1,724,344



Assumptions:

a   We have assumed that all of the existing 148 refineries in the
United States (i.e., respondents) would have at least one process unit
(affected facility) subject to the requirements of NSPS subpart GGG.  We
have further assumed that there will be no new respondents subject to
this rule over the three year period of this ICR since any new petroleum
refining process unit would be required to comply with recent equipment
leaks standards which are more stringent.       

b   This ICR uses the following labor rates: $97.46 per hour for
Executive, Administrative, and Managerial labor; $83.71 per hour for
Technical labor, and $42.55 per hour for Clerical labor.  These rates
are from the United States Department of Labor, Bureau of Labor
Statistics, March 19, 2005, (Table 2. Civilian Workers, by occupational
and industry group.(  The rates are from column 1, (Total compensation.(
 The rates have been increased by 110% to account for the benefit
packages available to those employed by private industry.

c  We have assumed that all sources are in compliance with initial rule
requirements including the initial performance test and notification
requirements .  We have assumed that usually 20 percent of the sources
would repeat performance tests due to failure.    

d   Monitoring of operations includes:  1) implementation of Standard
Operating Procedures (SOP) for operation and maintenance of  control
equipment; 2)  records of tank identification numbers; and monthly leak
detection inspection of control equipment.  

e   The rule requires existing sources to submit semi-annual reports.

f We have assumed that equipment leaks data will be recorded daily at an
average of 18 minutes or 0.3 hours per day.   

Table 2.  Annual Burden and Cost for The Federal Government: 

NSPS for Equipment Leaks of VOC in Petroleum Refineries

(40 CFR Part 60, Subpart GGG)

	Activity	

(A)

EPA person-

hours per

occurrence	

(B)

No. of

occurrences

per plant

per year

	

(C)

EPA person-

hours per

plant per

year

(C=AxB)	

(D)

Plants

per

year  a

	

(E)

Technical

person-hours

per year

(E=CxD)	

(F)

Management

person-hours

per year

(Ex0.05)

	

(G)

Clerical

person-

hours per

year

(Ex0.1)

	

(H)

Cost, $ b



Initial  Notifications   c       	

2	

1	

2	

0	

0	

0	

0	

$0.00



Reports of performance test       results   c	

8	

1.2	

9.6	

0	

0	

0	

0	

$0.00



Semi-annual  reports   d	

4	

2	

8	

148	

1,184	

59.2	

118.4	

$55,199.26



Subtotal Burden and Cost	

	

	

	

	

1,184	

59.2	

118.4	

$55,199.26



TOTAL ANNUAL BURDEN AND COST (rounded)	

	

	

	

	1,362	

$55,199



Assumptions:

a    We have assumed that all of the existing 148 refineries in the
United States (i.e., respondents) would have at least one process unit
(affected facility) subject to the requirements of NSPS subpart GGG.  We
have further assumed that there will be no new respondents subject to
this rule over the three year period of this ICR since any new petroleum
refining process unit would be required to comply with recent equipment
leaks standards which are more stringent.  b   This cost is based on
the following labor rates which incorporates a 1.6 benefits
multiplication factor to account for government overhead expenses: 
Managerial rate of $56.02 (GS-13, Step 5, $35.01 x 1.6), Technical rate
of $41.57 (GS-12, Step 1, $25.98 x 1.6), and Clerical rate of $22.50
(GS-6, Step 3, $14.06 x 1.6).  These rates are from the Office of
Personnel Management (OPM) (2005 General Schedule( which excludes
locality rates of pay.  

c   We have assumed that all existing sources are in compliance with the
initial rule requirements. 

d   The rule requires existing sources to
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