SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

STANDARDS OF PERFORMANCE

NSPS SUBPART GGG

EQUIPMENT LEAKS OF VOC IN PETROLEUM REFINERIES

OCTOBER 2006

1.  Identification of the Information Collection

	1(a)  Title of the Information Collection

ICR for NSPS Subpart GGG - Equipment Leaks of VOC in Petroleum
Refineries

	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.    SEQ
CHAPTER \h \r 1 The burden estimates presented in this ICR reflect
proposed amendments to the reporting and recordkeeping requirements in
Subpart GGG.

	Owners or operators of the affected facilities described must make
one-time-only notifications.  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 on which components are leaking VOCs. 
NSPS GGG references the compliance requirements of NSPS VV.  Owners or
operators are required to periodically (time period varies depending on
equipment type and leak history) record information identifying leaking
equipment, repair methods used to stop the leaks and dates of repair. 
Semiannual reports are required to measure compliance with the standards
of NSPS Subpart VV as referenced by NSPS Subpart GGG.  These
notifications, reports, and records are essential in determining
compliance; and are required, in general, 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.

	The Environmental Protection Agencies databases show that approximately
45 sources are currently subject to the standard, and it is estimated
that an additional 2 sources per year will become subject to the
standard in the next three years.  There have been no new refineries
built during the period of these regulations, and the increase is
expected to come solely from sources that meet the definition of
reconstruction or modification.  The labor hours are 8,317 per year and
the annual cost of this ICR will be $460,505.  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.

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, 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 nonair 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 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 Equipment Leaks of
VOC in Petroleum Refineries cause or contribute to air pollution that
may reasonably be anticipated to endanger public health or welfare. 
Therefore, NSPS were promulgated for this source category at 40 CFR part
60, subpart GGG.

	2(b)  Practical Utility/Users of the Data 

	The control of emissions of VOC from equipment leaks in petroleum
refineries requires not only the installation of properly designed
equipment, but also the operation and maintenance of that equipment. 
Emissions of VOC from equipment leaks in petroleum refineries are the
result of operation of the compressors and the group of all equipment
(e.g., valves, pumps, flanges, etc.) within a process unit in VOC
service.  These standards rely on the prevention of VOC emissions by the
work practice of proper leak detection and timely repair.  

The notifications required in these standards are used to inform the
Agency or delegated authority when a source becomes subject to these
standards.  The reviewing authority may then inspect the source to check
if the leaks are being detected and repaired and the standard is being
met.  Performance test reports are needed, as these are the Agency's
record of a source's initial capability to comply with the emission
standard and serve as a record of the operating conditions under which
compliance was achieved.  NSPS Subpart GGG references NSPS Subpart VV
for compliance.  

Monthly monitoring of compressors and equipment in VOC service under
NSPS Subpart GGG shall take place as specified in NSPS Subpart VV
section 60.485(b).  For valves, if no leaks are detected for two
successive months, monitoring may be performed once per quarter (see
§60.482-7(c)).  If a leak is detected, the equipment shall be monitored
monthly until a leak is not detected for two successive months.  Also,
leak location shall be recorded in a log, and this information shall be
kept available for two years.  Leaks shall be repaired within 15 days
and the date of successful repair shall be recorded in the log. 
Additionally, an owner or operator may use specified equipment
eliminating the need for monitoring, or seek approval of alternative
emission limitations under other various sections of 40 CFR subpart VV. 
Semiannual reports shall be submitted itemizing the information for each
month.  Notifications are used to inform the Agency, or delegated
authority when a source becomes subject to a standard.  The reviewing
authority may then inspect the source to check if the standard is being
met.  The semiannual reports are used for problem identification, as a
check on source operations and maintenance, and for compliance
determinations.  

The information generated by the monitoring, recordkeeping and reporting
requirements described in this ICR is used by the Agency to ensure that
facilities affected by the NSPS continue to identify and repair leaking
equipment and achieve compliance with the regulation.  Adequate
monitoring, recordkeeping, and reporting are necessary to ensure
compliance with these standards, as required by the Clean Air Act.  The
information collected from recordkeeping and reporting requirements is
also used for targeting inspections, and is of sufficient quality to be
used as evidence in court.

3.  Nonduplication, Consultations, and Other Collection Criteria

The recordkeeping and reporting requested is required under 40 CFR part
60, subpart GGG.  

	3(a)  Nonduplication

	If the subject standards have not been delegated, the information is
sent 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  

  SEQ CHAPTER \h \r 1 A public review and comment period will occur
following publication of the proposed amendments to the Standards of
Performance for Equipment Leaks of VOC in Petroleum Refineries (40 CFR
part 60, subpart GGG) in the Federal Register.

	3(c)  Consultations

  SEQ CHAPTER \h \r 1 	The EPA will provide a 60-day public comment
period after proposal of the amendments to the NSPS Subpart GGG.  All
affected parties will be given the opportunity to comment on the
proposed amendments during this period.  The EPA will consider all of
the comments received and may incorporate them in developing the final
amendments.

	During development of the proposed amendments, EPA held meetings and
conference calls with representatives of petroleum refining companies
and their trade associations (National Petroleum Refiners Association
and American Petroleum Institute); however, recordkeeping and reporting
requirements and related burden estimates were not discussed during
these meetings.  

	3(d)  Effects of Less Frequent Collection

	  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(e)  General Guidelines

	None of the reporting or recordkeeping requirements contained in 40 CFR
part 60, subpart GGG or otherwise pertinent to this request violate any
of the regulations established by OMB in 5 CFR 1320.6.

	3(f)  Confidentiality

	The required information consists of emissions data and other
information that have been determined not to be private.  However, any
information submitted to the Agency for which a claim of confidentiality
is made will be safeguarded according to the Agency policies set forth
in Title 40, Chapter 1, Part 2, Subpart B - Confidentiality of Business
Information (see 40 CFR 2; 41 FR 36902, September 1, 1976; amended by 43
FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR
17674, March 23, 1979).

	3(g)  Sensitive Questions

	None of the reporting or recordkeeping requirements contained in 40 CFR
part 60, subpart GGG or otherwise pertinent to this request contain
sensitive questions.

4.  The Respondents and the Information Requested

	4(a)  Respondents/SIC Codes

	The respondents of the recordkeeping and reporting requirements are
petroleum refineries where the affected compressors or group of
equipment within a process unit commenced construction, modification, or
reconstruction after January 4, 1983.  The SIC code for the respondents
affected by the standards is SIC (U.S. Standard Industrial
Classification) Code 2911 which corresponds to the NAICS (North American
Industry Classification System) 324110 for petroleum refineries where
the affected compressors or group of equipment within a process unit
commenced construction, modification, or reconstruction after January 4,
1983.

	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 GGG.  Although monitoring of the various components
may be required on a weekly, monthly, quarterly, semi-annual or annual
basis, given the number of components that must be monitored at any
facility, monitoring overall is essentially occurring daily.  Therefore,
it is assumed that the average record keeping time for each day’s
worth of monitoring is 0.3 hours and that monitoring is done 365 days a
year.  An estimated 0.12 hours per day are needed to complete the tasks
required by the proposed amendments.

	A source must make the following reports:

Notifications for 40 CFR Part 60, Subpart GGG	Citation

Construction/reconstruction	60.7(a)(1)

Anticipated startup	60.7(a)(2)

Actual startup	60.7(a)(3)

Physical or operational change	60.7(a)(4)

Initial performance test	60.8(d)

Alternative standard selected	60.487(d)

Reports for 40 CFR Part 60, Subpart GGG

	Initial performance test results	60.8(a)

Comply with the provisions of 60.487	60.592(e)

Semiannual reports (this provision is proposed to be amended)	60.486,
60.487(a), 60.487(b), 60.487(c)

Performance test 	60.8, 60.487(e)



	A source must keep the following records:

Recordkeeping for 40 CFR Part 60, Subpart GGG	Citation

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)

The date and instrument reading of each monitored component must be
recorded (this provision is proposed to be added)	60.486(a)

Each detected leak shall be recorded in a log and kept for 2 years (this
provision is proposed to be amended)	60.486(c)

Information pertaining to design requirements or closed vent systems and
control devices (this provision is proposed to be amended)	60.486(d)

Information pertaining to all equipment (this provision is proposed to
be amended)	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)



	Records are required to be retained for 2 years.

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 the required reports.

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 40 CFR Part 60, 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

	Following notification of startup, the reviewing authority might
inspect the source to determine whether the pollution control devices
are properly installed and operated.  Performance test reports are used
by the Agency to discern a source’s initial capability to comply with
the emission standard.  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 AIRS, which is
operated and maintained by EPA's Office of Air Quality Planning and
Standards.  AIRS is EPA’s database for the collection, maintenance,
and retrieval of compliance and annual emission inventory data for over
100,000 industrial and government-owned facilities.  EPA uses AIRS for
tracking air pollution compliance and enforcement by Local and State
regulatory agencies, and EPA Regional Offices and 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

	For this industry, there is a distribution of business sizes.  The
recordkeeping and reporting requirements were selected within the
context of this specific subpart and the specific process equipment and
pollutant.  A majority of the affected facilities 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.  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.

	For sources that install “leakless” components, monitoring may not
be required for those components.  Monitoring (and therefore,
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.

	5(d)  Collection Schedule

	The specific frequency for each information collection activity within
this request is shown in Table 2: Annual burden of reporting and
recordkeeping requirements as a result of NSPS Subpart GGG.

6.  Estimating the Burden and Cost of the Collection

	Table 2 documents the computation of individual burdens for the
recordkeeping and reporting requirements applicable to the industry for
the Subpart included in this ICR.  The individual burdens are expressed
under standardized headings believed to be consistent with the concept
of burden under the Paperwork Reduction Act.  Where appropriate,
specific tasks and major assumptions have been identified.  The type of
industry costs associated with the information collection activity in
the standards are labor costs for using the VOC monitors.  Monitoring
equipment for leaks is standard in the industry for safety reasons.  To
the extent possible, the requirements of this standard are consistent
with industry practice.  Consequently, there are no capital costs
associated with this standard.  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 8,317
person-hours.  These hours are based on Agency studies and background
documents from the development of the standards or test methods, Agency
knowledge and experience with the NSPS program, the previously approved
ICR, and any comments received.

	6(b)  Estimating Respondent Costs

		(i)  Estimating Labor Costs

	This ICR uses labor rates of $55.34 per hour for technical (most
activities) and $78.54 per hour for managerial (assumed needed only for
performance tests).  These rates are from the United States Department
of Commerce Bureau of Labor Statistics, March 2000, “Table 10. Private
industry, by occupational and industry group.”  The rates are from
column 1, “Total compensation.”  The wage rates have been increased
by 110% to account for the benefit packages available to those employed
by private industry.

 

		(ii)  Estimating Capital and Operations 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, or operation and maintenance costs.  The type of
industry costs associated with the information collection activity in
the standards are labor costs and maintenance costs for the VOC
monitors.  Monitoring equipment for leaks is standard in the industry
for safety reasons.  To the extent possible, the requirements of this
standard are consistent with industry practice.  Consequently, there are
no capital costs associated with this standard.

		(iii)  Capital/Start-up vs. Operating and Maintenance (O&M) Costs

	This is not applicable since this is a leak detection and repair
program with no continuous monitoring equipment, as stated in the
previous section.

	6(c)  Estimating Agency Burden and Cost

	The only costs to the Agency are those costs associated with analysis
of the reported information.  Publication and distribution of the
information are part of the AFS program.  Examination of records to be
maintained by the respondents will occur as part of the periodic
inspection of sources, which is part of EPA's overall compliance and
enforcement program. 

	The average annual Agency cost during the 3 years of the ICR is
estimated to be $19,130 (from Table 1).  This cost is based on the
average hourly labor rate at a GS12 step 1 times a 1.6 benefits
multiplication factor to account for government overhead expenses for a
total of $36.98.  Details upon which this estimate is based appear in
Table 1: Average annual EPA resource requirements resulting from NSPS
Subpart GGG. 

	

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

Respondent Universe:

Regulation Citation:  40 CFR Part 60, Subpart GGG	(A)

No. of New Source/Year	(B)

No. of Initial Reports for New Sources	(C)

No. of Existing Sources	(D)

No. of Reports for Existing Sources	(E)

Total Annual Responses

(AxB)+(CxD)

First year after proposal	2	4	45	2	98

Second year after proposal	2	4	47	2	102

Third year after proposal	2	4	49	2	106



	The number of total respondents in the second year is 49.  This number
is the sum of Column A and Column C of the second row in the Respondent
Universe table above.  The number represents the number of existing
sources plus the number of new sources averaged over the three-year
period.  It is shown in block 9, Respondents, on Part II of the
Paperwork Reduction Act Submission Worksheet.

	

	The number of Total Annual Responses in the second year is 102.  This
is the number in Column E of the second row in the Respondent Universe
table.  It is shown in block 10, Annual Number of Responses, on Part II
of the Paperwork Reduction Act Submission Worksheet.  The total annual
labor costs are $460,505.  The number of burden hours on which this
estimate is based, 8,317, are shown on Part II of the Paperwork
Reduction Act Submission Worksheet on block 11, Hour and Cost Burden. 
Details upon which this estimate is based appear in Table 2: Annual
burden of reporting and recordkeeping requirements as a result of NSPS
Subpart GGG.

	The total annual capital and O&M costs to the regulated entity are zero
dollars.  Capital and O&M costs are not applicable since this is a leak
detection and repair program with no continuous monitoring equipment
used.

	6(e)  Bottom Line Burden Hours and Cost Tables

	The bottom line burden hours and cost table for both the Agency and the
respondents appear below (Table 1 and Table 2).

	6(f)  Reasons for Change in Burden

	The increase in burden cost from the most recently approved ICR is due
to the proposal of amendments to the recordkeeping and reporting
requirements to NSPS Subpart VV and NSPS Subpart GGG.

	6(g)  Burden Statement

	The annual public reporting and recordkeeping burden for this
collection of information is estimated to average 804 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 currently valid OMB
control number.  The OMB control numbers for EPA's regulations are
listed in 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-OAR-2006-0699, which is available for online viewing at  
HYPERLINK "http://www.regulations.gov"  www.regulations.gov , or in
person viewing at the Air and Radiation Docket and Information Center in
the EPA Docket Center (EPA/DC), EPA West, Room 3334, 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 Air and Radiation Docket and
Information Center is (202) 566-1742.  An electronic version of the
public docket is available at www.regulations.gov.  This site can be
used to submit or view public comments, access the index listing of the
contents of the public docket, and to access those documents in the
public docket that are available electronically.  When in the system,
select “search,” then key in the Docket ID Number identified above. 
Also, you can send comments to the Office of Information and Regulatory
Affairs, Office of Management and Budget, 725 17th Street, NW,
Washington, D.C. 20503, Attention: Desk Officer for EPA.  Please include
the EPA Docket ID Number EPA-HQ-OAR-2006-0699 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: AVERAGE ANNUAL EPA RESOURCE REQUIREMENTS RESULTING FROM NSPS
SUBPART GGG.

Activity	(A)  EPA Hours/ Occurrence	(B)  Occurrences/ Plant/ Year	(C) 
EPA Hours/Plant Yeara	(D)  Plants/Year	(E)  EPA Hours/ Yearb

Initial Performance Tests (New Plants)	24	1	24	2	48

Repeat Performance Testsc (New Plants)	24	0.2	4.8	2	9.6

Report Review





	(New Plants)

Notification of construction	2	1	2	2	4

Notification of anticipated startup	0.5	1	0.5	2	1

Notification of actual startup	0.5	1	0.5	2	1

Notification of initial test	0.5	1.2	0.6	2	1.2

Review test results	8	1.2	9.6	2	19.2

(Existing Plants)

Emission Reports	4.2	2	8.4	49	412

Total Annual Hours



	496

Travel Expenses:

(1 person x 2 plants/year x 3 days/plant x $50 per diem) + ($250 round
trip/plant x 2 plants/year) = $800/year

Salary: d

(496 hours/year x $36.98/hour) = $18,330/year

Total Annual Cost = $800 + $18,330 = $19,130

a  A x B = C

b  C X D = E

c  Assume 20% of initial performance tests must be repeated due to
failure

d  Estimate an hourly wage of GS 12 Step 1 multiplied by a 1.6 benefits
multiplication factor to account for government overhead expenses for a
total of $36.98

TABLE 2: ANNUAL BURDEN OF REPORTING AND RECORDING REQUIREMENTS AS A
RESULT OF NSPS SUBPART GGGa

	(A)  Hours per Occurrence	(B)  Occurrences/ Respondent/Year	(C)  Hours/
Respondent/Year

(A x B)	(D)  Respondents/ Year	(E)  Hours/Year

(C x D)	(F)  Cost/Year

1. APPLICATIONS (Not Applicable)







2. SURVEY AND STUDIES (Not Applicable)







3. REPORT REQUIREMENTS







A. Read Instructions	1	1	1	2	2	111 c

B. Required Activities







Initial performance test	24	1	24	2	48	2,879 b

Repeat performance test	24	1	24	0.4 d	9.6	576 b

C. Create Information (Included in 3B)







D. Gather Existing Information (Included in 3E)







E. Write Report







Notification of construction or reconstruction	2	1	2	2	4	221 c

Notification of anticipated startup	2	1	2	2	4	221 c

Notification of actual startup	2	1	2	2	4	221 c

Notification of initial performance test	2	1	2	2	4	221 c

Report of performance test (Included in 3B)







Semiannual work practice reports	8.2	2	16.4	49 e	804	44,471 c

4. RECORDKEEPING REQUIREMENTS







A. Read Instructions (Included in 3A)







B. Plan Activities (Included in 3B)







C. Implement Activities (Included in 3B)







D. Develop Record System (Not Applicable)







E. Time to Enter Information







Records of operating parameters g	0.42	365 f	151.8	49 e	7,437	411,583 c

F. Train Personnel (Not Applicable)







G. Audits (Not Applicable)







5. TOTAL ANNUAL BURDEN



	8,317	$460,505

a  Estimating that there are approximately 6 plants (respondents) which
become subject over a 3-year period.  The number of new sources per year
equals 6/3 = 2.

b  Assume an average hourly wage of ($55.34 x 0.8E + $78.54 x 0.2E). 
This amount was multiplied by the hours per year in Column E.

c  Assume 100% technical rate at $55.34/hour.

d  Assume 20% of initial performance tests must repeat due to failure.

e  Assume operation is 365 days per year as specified in the NSPS review
document.

f  Assume that average number of affected facilities over the next three
years is estimated by the number of affected facilities in the second
year (45 + 2 + 2 = 49).

g  Although monitoring of the various components may be required on a
weekly, monthly, quarterly, semi-annual or annual basis, given the
number of components that must be monitored at any facility, monitoring
overall is essentially occurring daily.  Therefore, it is assumed that
the average record keeping time for each day’s worth of monitoring is
0.3 hours and that monitoring is done 365 days per year.  An estimated
0.12 hours per day are needed to complete the tasks required by the
proposed amendments.

	

