SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

	

NSPS for VOC Emissions from Petroleum Refinery Wastewater System 

1.  Identification of the Information Collection

1(a)  Title of the Information Collection

NSPS for VOC Emissions from Petroleum Refinery Wastewater System (40 CFR
part 60, subpart QQQ) (Renewal)

1(b)  Short Characterization/Abstract

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

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

Any owner or operator subject to the provisions of this part shall
maintain a file of these measurements, and retain the file for at least
two years following the date of such measurements, maintenance reports,
and records.  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 United States Environmental Protection
Agency (EPA) regional office.

Based on our consultations with industry representatives, there is an
average of one affected facility at each plant site and that each plant
site has only one respondent (i.e., the owner/operator of the plant
site).

Over the next three years, an average of 135 facilities per year will be
subject to the standard, and it is estimated that no additional sources
per year will become subject to the standard in the next three years.

There are approximately 135 VOC emissions from petroleum refinery
wastewater systems in the United States, which are all publicly owned
and operated by the petroleum refinery wastewater system industry.  None
of the 135 facilities in the United States are owned by either state,
local, tribal or the Federal Government.  They are all owned and
operated solely by privately owned for-profit businesses.  You can find
the burden to the “Affected Public” listed below in Table 1: Annual
Industry Burden and Cost - NSPS for VOC Emissions from Petroleum
Refinery Wastewater System (40 CFR part 60, subpart QQQ).  The Federal
government burden does not include work performed by Federal employees
only work performed by contractors, which could be found listed below in
Table 2: Average Annual EPA Burden - NSPS for VOC Emissions from
Petroleum Refinery Wastewater System (40 CFR part 60, subpart QQQ).

The Office of Management and Budget (OMB) approved the currently active
ICR without any “Terms of Clearance.”

2.  Need for and Use of the Collection

2(a)  Need/Authority for the Collection

The EPA is charged under section 111 of the Clean Air Act (CAA), as
amended, to establish standards of performance for new stationary
sources that reflect: 

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

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

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

(A) Establish and maintain such records; (B) make such reports; (C)
install, use, and maintain such monitoring equipment, and use such audit
procedures, or methods; (D) sample such emissions (in accordance with
such procedures or methods, at such locations, at such intervals, during
such periods, and in such manner as the Administrator shall prescribe);
(E) keep records on control equipment parameters, production variables
or other indirect data when direct monitoring of emissions is
impractical; (F) submit compliance certifications in accordance with
Section 114(a)(3); and (G) provide such other information as the
Administrator may reasonably require.

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

2(b)  Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensure
compliance with the applicable regulations which where promulgated in
accordance with the Clean Air Act.  The collected information is also
used for targeting inspections and as evidence in legal proceedings.

Performance tests are required in order to determine an affected
facility’s initial capability to comply with the emission standard. 
Continuous emission monitors are used to ensure compliance with the
standard at all times.  During the performance tests, a record of the
operating parameters under which compliance was achieved may be recorded
and used to determine compliance in place of a continuous emission
monitor.

The notifications required in the standard are used to inform the Agency
or delegated authority when a source becomes subject to the requirements
of the regulations.  The reviewing authority may then inspect the source
to ensure that the pollution control devices are properly installed and
operated, that leaks are being detected and repaired, and that the
standard is being met.  The performance test may also be observed.

The required semiannual and quarterly reports are used to determine
periods of excess emissions, identify problems at the facility, verify
operation/maintenance procedures, and for compliance determinations.

3.  Nonduplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR part
60, subpart QQQ.

3(a)  Nonduplication

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

3(b)  Public Notice Required Prior to ICR Submission to OMB

An announcement of a public comment period for the renewal of this ICR
was published in the Federal Register (72 FR 10735) on March 9, 2007. 
No comments were received on the burden published in the Federal
Register.

3(c)  Consultations

The Agency’s industry experts have been consulted, and the Agency’s
internal data sources and projections of industry growth over the next
three years have been considered.  The primary source of information as
reported by industry, in compliance with the recordkeeping and reporting
provisions in the standard, is the Online Tracking Information System
(OTIS) which is operated and maintained by EPA's Office of Compliance. 
OTIS is EPA’s database for the collection, maintenance, and retrieval
of all compliance data.  The growth rate for the industry is based on
our consultations with the Agency’s internal industry experts.
Approximately 135 respondents will be subject to the standard over the
three year period covered by this ICR.

Industry trade associations and other interested parties were provided
an opportunity to comment on the burden associated with the standard as
it was being developed and the standard has been previously reviewed to
determine the minimum information needed for compliance purposes.

It is our policy to respond after a thorough review of comments received
since the last ICR renewal as well as those submitted in response to the
first Federal Register notice.

3(d)  Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of
assurance that facilities are continuing to meet the standards. 
Requirements for information gathering and recordkeeping are useful
techniques to ensure that good operation and maintenance practices are
applied and emission limitations are met.  If the information required
by these standards was collected less frequently, the proper operation
and maintenance of control equipment and the possibility of detecting
violations would be less likely.

3(e)  General Guidelines

These reporting or recordkeeping requirements do not violate any of the
regulations promulgated by OMB under 5 CFR part 1320, section 1320.5.

 	

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 (CBI) (see 40 CFR 2; 41 FR
36902, September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43
FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979).

3(g)  Sensitive Questions

None of the reporting or recordkeeping requirements contain sensitive
questions.

4.  The Respondents and the Information Requested

4(a)  Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are
source category description.  The United States Standard Industrial
Classification (SIC) code for the respondents affected by the standards
is SIC 2911, which corresponds to the North American Industry
Classification System (NAICS) 324110 for source category description. 
The respondents to the recordkeeping and reporting requirements are
petroleum refineries.

4(b)  Information Requested

None of these reporting or recordkeeping requirements violate any of the
regulations established by OMB at 5 CFR part 1320, section 1320.5.

(i)  Data Items

In this ICR, all the data recorded or reported is required by the New
Source Performance Standards for VOC Emissions from Petroleum Refinery
Wastewater Systems (40 CFR part 60, subpart QQQ).

A source must make the following reports:

Notifications

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

Notification of modification	60.7(a)(4)

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

Notification of initial performance test	60.8(a)

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

Notification of election to construct and operate a floating roof on an
oil-water separator tank or other subject auxiliary equipment
60.693-2(b) and 60698(a)

Notification of intent to use an alternative means of emission
limitation	60.694(c)

Notification of intent to use a VOC control device other than a carbon
absorber to meet the requirement of 60.692-5(a), with information
describing the control device and the process parameters being monitored
60.695(b)

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

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

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

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

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

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

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

Semiannual reporting on control device performance	60.698(d)



A source must keep the following records:

Recordkeeping 

Maintain records of startups, shutdowns, malfunctions of affected
facilities; malfunctions of control devices; and periods where the
continuous monitoring system is inoperative	60.7(b)

Maintain records of measurements, performance evaluations, calibration
checks, adjustments and maintenance related to continuous monitoring
systems	60.7(f)

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

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

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

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

Maintain records of location, date and corrective actions for closed
vent systems and completely closed drain systems our of compliance
60.697(d)

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

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

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

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

Maintain records of location, plans or specifications for exempted storm
water sewer systems	60.697(h)

Maintain records of location, plans or specification for exempted
ancillary equipment	60.697(i)

Maintain records of location, plans or specifications for exempted
non-contact cooling water systems.	60.697(j)



Electronic Reporting

Some of the respondents are using monitoring equipment that
automatically records parameter data.  Although personnel at the
affected facility must still evaluate the data, internal automation has
significantly reduced the burden associated with monitoring and
recordkeeping at a 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.

Respondent Activities

Read instructions.

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

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

Write the notification 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.



	Currently, sources are using monitoring equipment that provides
parameter data in an automated way e.g., continuous parameter monitoring
system.  Although personnel at the source still need to evaluate the
data, this type of monitoring equipment has significantly reduced the
burden associated with monitoring and recordkeeping.

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

5(a)  Agency Activities

EPA conducts the following activities in connection with the
acquisition, analysis, storage, and distribution of the required
information.

Agency Activities

Observe initial performance tests and repeat performance tests if
necessary.

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

Audit facility records.

Input, analyze, and maintain data in the Online Tracking Information
System (OTIS).



5(b)  Collection Methodology and Management

Following notification of startup, the reviewing authority might inspect
the source to determine whether the pollution control devices are
properly installed and operational.  Performance test reports are used
by the Agency to discern a source’s initial capability to comply with
the emission standard, and note the operating conditions under which
compliance was achieved.  Data and records maintained by the respondents
are tabulated and published for use in compliance and enforcement
programs.  The semiannual reports are used for problem identification,
as a check on source operation and maintenance, and for compliance
determinations.

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

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

5(c)  Small Entity Flexibility

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

5(d)  Collection Schedule

The specific frequency for each information collection activity within
this request is shown in Table 1: Annual Industry Burden, NSPS for VOC
Emissions from Petroleum Refinery Wastewater Systems (40 CFR part 60,
subpart QQQ).

6.  Estimating the Burden and Cost of the Collection

Table 1 documents the computation of individual burdens for the
recordkeeping and reporting requirements applicable to the industry for
the subpart included in this ICR.  The individual burdens are expressed
under standardized headings believed to be consistent with the concept
of burden under the Paperwork Reduction Act.  Wherever 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 to be 9,237
(Total Labor Hours from Table 1).  These hours are based on Agency
studies and background documents from the development of the regulation,
Agency knowledge and experience with the NESHAP program, the previously
approved ICR, and any comments received.

6(b)  Estimating Respondent Costs

(i)  Estimating Labor Costs 

This ICR uses the following labor rates: 

Managerial	$105.86 ($50.41 + 110%)  

Technical	$92.61   ($44.10 + 110%)

Clerical	$45.32   ($21.58 + 110%)

These rates are from the United States Department of Labor, Bureau of
Labor Statistics, December 2006, 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.

(ii)  Estimating Capital/Startup and Operation and Maintenance Costs

The only costs to the regulated industry resulting from information
collection activities required by the subject standard are labor costs. 
The type of industry costs associated with the information collection
activities in the subject standard are both labor costs which are
addressed elsewhere in this ICR and the costs associated with continuous
monitoring.  The capital/startup costs are one-time costs when a
facility becomes subject to the regulation.  The annual operation and
maintenance costs are the ongoing costs to maintain the monitor and
other costs such as photocopying and postage.

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

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

(A)

Continuous Monitoring Device	(B)

Capital/Startup Cost for One Respondent	(C)

Number of New Respondents	(D)

Total Capital/Startup Cost

(B X C)	(E)

Annual O&M Costs for One Respondent	(F)

Number of Respondents with O&M	(G)

Total O&M,

(E X F)

Portable VOC analyzer for non-regenerative carbon absorber 	$2,960	0	0
$130	135	$17,550

 	

The total capital/startup costs for this ICR are zero.  This is the
total of column D in the above table. 

The total operation and maintenance (O&M) costs for this ICR are
$17,550.  This is the total of column G. 

The average annual cost for capital/startup and operation and
maintenance costs to industry over the next three years of the ICR is
estimated to be $17,550.

6(c)  Estimating Agency Burden and Cost

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

The average annual Agency cost during the three years of the ICR is
estimated to be $104,576.

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

	Managerial	$58.18 (GS-13, Step 5, $36.36 + 60%) 

	Technical	$43.17 (GS-12, Step 1, $26.98 + 60%)

	Clerical	$23.36 (GS-6, Step 3, $14.60 + 60%)

These rates are from the Office of Personnel Management (OPM) 2007
General Schedule which excludes locality rates of pay.  The rates have
been increased by 60% to account for the benefit packages available to
government employees.  Details upon which this estimate is based appear
in Table 2: Average Annual EPA Burden, NSPS for VOC Emissions from
Petroleum Refinery Wastewater Systems (40 CFR part 60, subpart QQQ),
below.

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

	

Based on our research for this ICR, on average over the next three
years, approximately 135 existing respondents will be subject to the
standard.  It is estimated that no additional respondents per year will
become subject.  The overall average number of respondents, as shown in
the table below is 135 per year.

The number of respondents is calculated using the following table that
addresses the three years covered by this ICR.  

Number of Respondents

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	135	0	0	135

2	0	135	0	0	135

3	0	135	0	0	135

Average	0	135	0	0	135

1 New respondent include sources with constructed, reconstructed and
modified affected facilities.  In this standard existing respondents
submit initial notifications.

To avoid double-counting respondents, column D is subtracted.  As shown
above, the average Number of Respondents over the three-year period of
this ICR is 135.

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

Notification of construction/reconstruction	0	1	n/a	0

Notification of modification	0	1	n/a	0

Notification of actual startup 	0	1	n/a	0

Initial certification of equipment and inspections	0	1	n/a	0

Initial inspection report detailing emission problems	0	1	n/a	0

Notifications of various intent	0	1	n/a	0

Demonstration for alternative operational or process parameter	0	1	n/a	0

Notification of delay in compliance	0	1	n/a	0

Semiannual report	135	2	n/a	270

Notification of initial performance test	0	1	n/a	0



	Total	270



The number of total respondents is 135

The number of Total Annual Responses is 270.  This is the number in
column E of the Respondent Universe and Number of Responses per year in
table above.

The total annual labor costs are $822,810.  Details regarding these
estimates may be found in Table 1: Annual Industry Burden, NSPS for VOC
Emissions from Petroleum Refinery Wastewater Systems (40 CFR part 60,
subpart QQQ), below.

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 shown in Tables 1 and 2, respectively,
and summarized below. 

(i) Respondent Tally

The total annual labor costs are $822,810.  Details regarding these
estimates may be found in Table 1. Annual Respondent Burden and Cost:
NSPS VOC Emissions from Petroleum Refinery Wastewater Systems (40 CFR
part 60, subpart QQQ), below.  Furthermore, the annual public reporting
and recordkeeping burden for this collection of information is estimated
to average 34 hours per response.

The total annual capital/startup and O&M cost to the regulated entity
are $17,550.

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is
estimated to be 2,484 labor hours at a cost of $104,576.  See Table 2.
Annual Agency Burden and Cost: NSPS for VOC Emissions from Petroleum
Refinery Wastewater Systems (40 CFR part 60, subpart QQQ), below.

6(f)  Reasons for Change in Burden

There is no change in the labor hours in this ICR compared to the
previous ICR.  This is due to two considerations.  First, the
regulations have not changed over the past three years and are not
anticipated to change over the next three years.  Secondly, the growth
rate for the industry is very low, negative or non-existent, so there is
no significant change in the overall labor hours.

There is however, a change in the cost estimate.  The previous ICR used
a cost figure that was rounded-up ($18,000).  This ICR uses the exact
cost figure ($17,550) resulting in a small cost decrease.

Since there are no changes in the regulatory requirements and there is
not significant industry growth, the labor hours in the previous ICR are
used in this ICR and there is no change in the labor hours to industry.

6(g)  Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 34 hours per response.  Burden
means the total time, effort, or financial resources expended by persons
to generate, maintain, retain, or disclose or provide information to or
for a Federal agency.  This includes the time needed to review
instructions; develop, acquire, install, and utilize technology and
systems for the purposes of collecting, validating, and verifying
information, processing and maintaining information, and disclosing and
providing information; adjust the existing ways to comply with any
previously applicable instructions and requirements; train personnel to
be able to respond to a collection of information; search data sources;
complete and review the collection of information; and transmit or
otherwise disclose the information.

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

To comment on the Agency's need for this information, the accuracy of
the provided burden estimates, and any suggested methods for minimizing
respondent burden, including the use of automated collection techniques,
EPA has established a public docket for this ICR under Docket ID Number
EPA-HQ-OECA-2007-0044.  An electronic version of the public docket is
available at http://www.regulations.gov which may be used to obtain a
copy of the draft collection of information, submit or view public
comments, access the index listing of the content of the docket, 

and to access those documents in the public docket that are available
electronically.  When in the system, select “search” than key in the
docket ID number identified in this document.  The documents are also
available for public viewing at the Enforcement and Compliance Docket
and Information Center in the EPA Docket Center (EPA/DC), EPA West, Room
3334, 1301 Constitution Avenue, N.W., Washington, DC.  The EPA Docket
Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday
through Friday, excluding legal holidays.  The telephone number for the
Reading Room is (202) 566-1744, and the telephone number for the
Enforcement and Compliance Docket and Information Center Docket is (202)
566-1752.  Also, you can send comments to the Office of Information and
Regulatory Affairs, Office of Management and Budget, 725 17th Street,
N.W., Washington, DC 20503, Attention: Desk Officer for EPA.  Please
include the EPA Docket ID Number EPA-HQ-OECA-2007-0044 and OMB Control
Number 2060-0172 in any correspondence.

Part B of the Supporting Statement

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

Table 1:  Annual Respondent Burden and Cost – NSPS for VOC Emissions
from Petroleum Refinery Wastewater System (40 CFR part 60, subpart QQQ)

 	(A)	(B)	(C)	(D)	(E)	(F)	(G)	 (H) 

 Burden item 	Person- hours per occurrence	No. of occurrences per
respondent per year	Person- hours per respondent per year (C=AxB)
Respondents per year (a)	Technical person- hours per year (E=CxD)
Management person-hours per year (Ex0.05)

	Clerical person-hours per year 

(Ex0.1)

	Cost {$} (b) 

1. Applications	N/A	 	 	 	 

	 

2. Survey and Studies	N/A	 	 	 	 

	 

3. Reporting requirements	 	 	 	 	 

	 

    A.  Read instructions	2	1	2	135	270	13.5	27	$27,657.45

    B.  Required activities









      1.  Inspect drain systems	2	12	24	135	3,240	162	324	$331,889.40

          2.  Inspect oil-water separators	8	2	16	135	2,160	108	216
$221,259.60

          3.  Performance test	330	1	330	0	0	0	0	$0

     C.   Create information 	See 3B







	     D.   Gather existing information	See 3E







	     E.   Write report  









    Notification of  construction/

    reconstruction	2	1	2	0	0	0	0	$0

    Notification of modification	2	1	2	0	0	0	0	$0

    Notification of actual startup	2	1	2	0	0	0	0	$0

    Initial certification of equipment

    and inspections	2	1	2	0	0	0	0	$0

    Initial inspection report detailing

    emission problems	2	1	2	0	0	0	0	$0

    Various notifications of intent	2	1	2	0	0	0	0	$0

    Demonstration for alternative

    operational or process parameter	2	1	2	0	0	0	0	$0

    Notification of delay in

    compliance	2	1	2	0	0	0	0	$0

    Semiannual report	8	2	16	135	2,160	108	216	$221,259.60

    Notification of initial

    performance test	2	1	2	0	0	0	0	$0

    Results of performance test	See 3B







	4.  Recordkeeping requirements









  A.  Read instructions	See 3A







	      B.  Plan activities	N/A





	  

      C.  Implement activities	N/A





	  

  D. Develop record system 	N/A





	  

      E.  Enter information                                             
                                                                        
  	1.5	1	1.5	135	202.5	10.13	20.25	$0

      F.  Train personnel	N/A







	  G.  Audits	N/A







	Subtotal



	8,032.5	401.63	803.25	$822,809.67

TOTAL ANNUAL BURDEN AND COST (rounded)





9,237

  $822,810



Assumptions:

a.  We have assumed that the average number of respondents that will be
subject to the rule will be 135.  There will be no additional new
sources per year that will become subject to the rule over the
three-year period of this ICR.

b.  This ICR uses the following labor rates: $105.86 per hour for
Executive, Administrative, and Managerial labor; $92.61 per hour for
Technical labor, and $45.32 per hour for Clerical labor.  These rates
are from the United States Department of Labor, Bureau of Labor
Statistics, December 2006, “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.

c.  We have assumed that each respondent will read instructions once per
year.

d.  We have assumed that each respondent will take two hours to inspect
drain systems twelve time per year.

e.  We have assumed that it will take eight hours for each respondent to
inspect oil-water separators two time per year.

f.  We have assumed that each respondent will take eight hours to write
the semiannual report two time per year.















Table 2:  Average Annual EPA Burden – NSPS VOC Emissions from
Petroleum Refinery Wastewater System (40 CFR part 60, subpart QQQ)

 	(A)	(B)	(C)	(D)	(E)	(F)	(G)	 (H) 

Activity 	EPA person- hours per occurrence	No. of occurrences per plant 

per year	EPA person- hours per plant per year (C=AxB)	Plants per year
(a)	Technical person- hours per year (E=CxD)	Management person-hours per
year (Ex0.05)

	Clerical person-hours per year 

(Ex0.1)

	Cost {$} (b) 

Report Review









     Notification of  construction/ 

     reconstruction	2	1	2	0	0	0	0	$0

 Notification of modification	2	1	2	0	0	0	0	$0

     Notification of actual startup	2	1	2	0	0	0	0	$0

     Initial certification for equipment and 

     inspections	2	1	2	0	0	0	0	$0

     Initial inspection detailing emission 

     Problems	2	1	2	0	0	0	0	$0

     Notification of various intent c	2	1	2	0	0	0	0	$0

     Demonstration for alternative

     operational or process parameter	2	1	2	0	0	0	0	$0

     Notification of delay in compliance	2	1	2	0	0	0	0	$0

     Notification of initial performance

     Test	2	1	2	0	0	0	0	$0

     Initial performance test report for

     Flares	2	1	2	0	0	0	0	$0

     Review of semiannual reports d	8	2	16	135	2,160	108	216

	Subtotal



	2,160	108	216	$104,576.40

TOTAL ANNUAL BURDEN AND COST (rounded)





2,484

  $104,576



Assumptions:

a.  We have assumed that the average number of respondents that will be
subject to the rule will be 135There will be no additional new sources
that will become subject to the rule over the three-year period of this
ICR.

b.  The cost is based on the following labor rate which incorporates a
1.6 benefits multiplication factor to account for government overhead
expenses.  Managerial rates of $58.18 (GS-13, Step 5, $36.36x1.6),
Technical rate of $43.17 (GS-12, Step 1, $26.96 x 1.6), and Clerical
rate of $23.36 (GS-6, Step 3, $14.60 x 1.6).  These rates are from the
Office of Personnel Management (OPM) “2007 General Schedule” which
excludes locality rates of pay.

c.  The following notification review is included: election to construct
and operate a completely closed drain system; election to construct and
operate a floating roof; intent to use an alternative means of emission
limitation; and intent to use a VOC control device other than a carbon
absorber to meet the requirements of 60.692-5(a).

d. We have assumed that it will take 8 hours two times per year to
review each semiannual report.





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