	

SF-83 SUPPORTING STATEMENT

	ENVIRONMENTAL PROTECTION AGENCY

NSPS for Bulk Gasoline Terminals (40 CFR part 60, subpart XX)

1.  Identification of the Information Collection

	1(a)  Title of the Information Collection

	NSPS for Bulk Gasoline Terminals (40 CFR part 60, subpart XX).

	1(b)  Short Characterization/Abstract

	The New Source Performance Standards (NSPS) were proposed on December
17, 1980 and promulgated on August 18, 1983, and amended on December 22,
1983.  These standards apply to the total of all loading racks at bulk
gasoline terminals which deliver liquid product into gasoline tank
trucks and for which construction, modification or reconstruction
commenced after the date of proposal.  A bulk gasoline terminal is any
gasoline facility which receives gasoline by pipeline, ship or barge,
and has a gasoline throughput greater than 75,700 liters per day.  The
affected facility includes the loading arms, pumps, meters, shutoff
valves, relief valves, and other piping and valves necessary to fill
delivery tank trucks.  Volatile organic chemicals (VOCs) are the
pollutants regulated under this subpart.   

	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 dates 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.  These notifications, reports and records are required, in
general, of all sources subject to NSPS.

	Monitoring requirements specific to bulk gasoline terminals are listed
in 40 CFR 60.505 of this subpart.  These requirements consist mainly of
identifying and documenting vapor tightness for each gasoline tank truck
that is loaded at the affected facility, and notifying the owner or
operator of each tank truck that is not vapor-tight.  The owner or
operator must also perform a monthly visual inspection for liquid or
vapor leaks, and maintain records of these inspections at the facility. 


	This information is being collected to assure compliance with 40 CFR
part 60, subpart XX.  In general, 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. Records of all replacements or additions of components shall be
kept on file for at least three years.  The reporting requirements for
this industry currently include only the initial notifications and
initial performance test report listed above.  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.

	Approximately 40 sources (i.e., bulk terminals with a gasoline
throughput greater than 75,700 liters/day) are currently subject to the
standard.  Due to consolidation of several industry refiners, no new
sources are expected to become subject to the standard over the next
three years.

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 at the Environmental Program of the National Petrochemical and
Refiners Association in Washington, D.C.  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 Clean Air Act (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.  

	For the present rule, though the retention of records for three years
of all replacements or additions of components and for two years of
monthly leak inspections and notification reports at the terminal allow
EPA to establish the compliance history of the respondent for purposes
of determining the appropriate level of enforcement action.  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) code(s) and corresponding
North American Industry Classification System (NAICS) for the
respondents are listed below. 

	Regulation		SIC Codes		NAICS Codes

New Source Performance Standards, 40 CFR, part 60, subpart XX, Bulk
Gasoline Terminals	5171	42271

	

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

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

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

Notification of performance test.	40 CFR 60.8(d)

Notifying the owner or operator of each nonvapor-tight gasoline truck
loaded	40 CFR 60.502(e)(4)



Reports

Reporting performance test results.	40 CFR 60.8(a)

	

	A source must maintain the following records:

Recordkeeping 

Startups, shutdowns, malfunctions, periods where the continuous
monitoring system is inoperative.	40 CFR 60.7(b)

Record the tank identification number as each gasoline tank truck is
loaded.	40 CFR 60.502(e)(2)

Record each leak detected during each calendar month inspection of
control equipment during loading operations.	40 CFR 60.502(j)

Record of documentation for tank truck vapor tightness - kept on
permanent record.	40 CFR 60.505(a)

Record of monthly leak inspection required under 60.502(j) for 2 years.
40 CFR 60.505(c)

Record of notifications under 60.502(e)(4) for 2 years.	40 CFR 60.505(d)

Records of replacement parts or additions for 3 years.	40 CFR 60.505(f)

Annual update of records of tank truck vapor tightness.	40 CFR 60.505(b)



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.

		(ii)  Respondent Activities	

Read instructions

Perform initial performance test, Reference Methods 2A, 2B, 21, 25A,
25B, and 27, and repeat performance tests if necessary

Write the notifications and reports listed above

Enter information required to be recorded above

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

Developing, acquiring, installing, and utilizing technology and systems
for the purpose of processing and maintaining information

Developing, acquiring, installing, and utilizing technology and systems
for the purpose of disclosing and providing information

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

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

Transmitting, or otherwise disclosing the information



	Regulatory agencies, to the extent possible, are relying more on
automated techniques such as electronic submissions of reports, and are
improving their tracking systems and database systems to enhance the use
of these techniques.  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.

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.

	EPA conducts the following activities in connection with the
acquisition, analysis, storage, and distribution of the information
required under 40 CFR part 60, subpart XX:

Observes initial performance tests and repeat performance tests if
necessary

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

Audits facility records

Inputs and maintains 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 through 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

	A majority of the affected facilities 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.  Specifically, sources are required to maintain records
of its operations at the terminal, however, no periodic reports are
required to be submitted.  

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

	5(d)  Collection Schedule

	The specific frequency for each information collection activity within
this request is shown in Table 1, 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 to be 13,168
hours.  The annual burden to industry is shown in Table 1.  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% 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 activities in the subject standards is labor cost which is
addressed elsewhere in this ICR.  There are no capital/startup and
operation and maintenance costs associated with continuous monitoring
equipment.  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(s) and other costs
such as photocopying and postage.

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

	The average annual cost for capital/startup and operation and
maintenance cost to industry over the next three years of the ICR is
zero because no continuous monitoring equipment is required by 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

	There is no Agency burden associated with this standard.  The lack of
an annual Agency labor burden is based on the assumption that there will
be no new bulk gasoline terminals submitting initial notifications
during the next three years, and the fact that this rule does not
require sources to submit periodic reports.  The average annual Agency
cost during the three years of the ICR is shown in Table 2, attached.

	The Agency annual 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 1	(B)

Number of Existing Respondents	(C)

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

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

Number of Respondents

(E=A+B+C-D)



1	

0	

0	

40	

0	

40



2	

0	

0	

40	

0	

40



3	

0	

0	

40	

0	

40



Average	

0	

0	

40	

0	

40

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

	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

That Submit Responses	(C)

Number of Responses	(D)

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

Total Annual Responses 

E=(BxC)+D



Initial Notifications	

0	

0	

0	

0



Report of Performance Test 	

0	

0	

0	

0



Periodic Reports 	

0	

0	

0	

0



Records of operations	

40	

0	

40	

40



	

	

	

Total	

40



	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 burden and cost to industry may be found in
Table 1, attached.

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

	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.  

		(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 329 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, attached.

	6(f)  Reasons for Change in Burden

	The increase in labor burden to industry from the most recently
approved ICR from 11,420 to 13,168 is due to adjustments.  This increase
in labor burden is due to a correction of the frequency of recording
leaks detection inspection data from one occurrence per year to monthly
occurrences as required by the rule, and the inclusion of labor hours
for the management and clerical employees.  The total industry cost also
increased from $631,983 to $1,062,809, as a result of these changes and
the use of an updated technical labor rate.  

	The reason for an increase in labor hours is due to a correction of the
frequency of recording leaks detection inspection data from one
occurrence per year to monthly occurrences per year as required by the
rule.  In addition, the burden calculation for the renewal of this ICR
includes labor hours for the management and clerical employees, as well
as updated labor rates for technical employees.   

	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.

	There was no Federal Government burden associated with the review of
initial notifications and performance test reports by new sources;
therefore, there is no change in this burden category.

	6(g)  Burden Statement

	The annual public reporting and recordkeeping burden for this
collection of information is estimated to average 329 hours (rounded)
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-2005-0017, which is available for public viewing at the Enforcement
and Compliance Docket and Information Center in the EPA Docket Center
(EPA/DC), EPA West, Room B102, 1301 Constitution Avenue, NW, Washington,
DC.  The EPA Docket Center Public Reading Room is open from 8:30 a.m. to
4:30 p.m., Monday through Friday, excluding legal holidays.  The
telephone number for the Reading Room is (202) 566-1744, and the
telephone number for the Enforcement and Compliance Docket and
Information Center 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-2005-0017 and OMB Control Number 2060-0006 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 Bulk Gasoline Terminals (40 CFR part 60, subpart XX) (Renewal)

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    	

60	

1	

60	

0	

0.0	

0.0	

0.0	

$0.00



   ii.  Repeat Performance tests  c    	

60	

0.2	

12	

0	

0.0	

0.0	

0.0	

$0.00

   iii.  Monitoring of operations          and equipment:  d	Included in
5E







	

D.  Gather Existing Information	

Included in 4B and 5E	

	

	

	

	

	





E.  Write report   a, c 	

	

	

	

	

	

	

	





   i.  Notification of compliance           status 	

2	

1	

2	

0	

0.0	

0.0	

0.0	

$0.00



   ii.  Notification of actual                  startup	

2	

1	

2	

0	

0.0	

0.0	

0.0	

$0.00



   iii.  Notification of                            construction/
modification   a	

2	

1	

2	

0	

0.0	

0.0	

0.0	

$0.00



   iv.  Notification of                            Performance Test 	

2	

1	

2	

0	

0.0	

0.0	

0.0	

$0.00



   v.  Reports of performance               test results	

Included in  4B









   vi.  Operation and                           maintenance reports 	N/A







	

    vii.  Semi-annual reports   e      	

N/A







	

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
includes:   f













    i.  Records of  startup, shutdown, malfunction, etc.	1.5	50	75	40
3,000	150	300	

$278,514



    ii.  Records of tank identification numbers                    	

0.1	

2,100	

210	

40	

8,400	

420	

840	

$770,839.20

    iii.  Leak detection records of    monthly control equipment 

inspections	

0.1	

12	

1.2	

40	

48	

2.4	

4.8	

$4,456.22



F.  Time to train personnel	

N/A	

	

	

	

	

	

	





G. Time for audits	

N/A	

	

	











TOTAL LABOR  BURDEN AND COST  	

	

	

	

	

11,448	

572.4	

1,148	

$1,062,809.42



TOTAL LABOR HOURS (Rounded)	

	

	

	

	

13,168	

$1,062,809



Assumptions:

a   There are an estimated  40 respondents which are subject to this
standard.  We have assumed that there will be no new net growth for this
industry over the three year period of this ICR.   In addition, we have
assumed that there will be no new lines constructed over the three year
period.

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 initial performance test.  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     There will be no semi-annual reports.

f  We have assumed that recordkeeping will take sources the following: 
records of SSM will occur once per week or 50 times per year; 6 minutes
or 0.1 hour to enter each tank identification number; and an average of
six tank trucks loading each day of 350 days of a year (6x350 days per
year=2,100). 

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

NSPS for Bulk Gasoline Terminals (40 CFR part 60, subpart XX) (Renewal)

	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	

N/A







	

Subtotal Burden and Cost	

	

	

	

	

0	

0	

0	

     $0.00



TOTAL ANNUAL BURDEN AND COST (rounded)	

	

	

	

	0	

          $0



Assumptions:

a   We have assumed that there are approximately two respondents
currently operating in the United States.  It is estimated that no
additional respondents will become subject to the regulation in the next
three years based on information available on the sector.  

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   Not applicable.  The rule does not required periodic reports.   

	

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