SUPPORTING STATEMENT

NSPS FOREQUIPMENT LEAKS OF VOC IN PETROLEUM REFINERIES

(40 CFR PART 60, SUBPARTS GGG and GGGa)

Part A of the Supporting Statement

1.  Identification of the Information Collection

	1(a)  Title of the Information Collection

	NSPS for Equipment Leaks of VOC in Petroleum Refineries (40 CFR part
60, subparts GGG and GGGa) (Final Rule), ICR 0983.10, OMB Control Number
2060-0067.

	1(b)  Short Characterization/Abstract

	This information collection request (ICR) is for the New Source
Performance Standards (NSPS) for Equipment Leaks of VOC (Volatile
Organic Compounds) in Petroleum Refineries in 40 CFR part 60, subparts
GGG and GGGa.  The NSPS in subpart GGG 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.  Amendments to subpart GGG were proposed on
November 7, 2006 that would have added new standards and compliance
requirements.  In response to public comments, all new requirements are
being incorporated in a new subpart GGGa that applies to sources that
commence construction, reconstruction, or modification after November 7,
2006.  The final amendments to subpart GGG involve only clarifications
and additional compliance options.    SEQ CHAPTER \h \r 1 The burden
estimates presented in this ICR reflect the reporting and recordkeeping
requirements in both subparts for the 3 years after November 7, 2006.

	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 Subpart GGG references the compliance requirements of NSPS Subpart
VV, and NSPS Subpart GGGa references the compliance requirements of NSPS
Subpart VVa.  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 Subparts VV and VVa as
referenced by NSPS Subparts GGG and GGGa.  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 Agency’s (EPA’s) databases show that
approximately 45 sources are currently subject to Subpart GGG.  This
number is not expected to change in the 3 years after November 7, 2006. 
In addition, although it is expected that no new refineries will be
built in this 3-year period, it is estimated that an additional 10
refiners per year will become subject to Subpart GGGa as refiners
construct new process units or either reconstruct or modify existing
process units.  For Subpart GGG, the labor hours are 6,495 per year and
the annual cost of the ICR will be $508,970.  For Subpart GGGa, the
labor hours are 4,216 per year and the annual cost of the ICR will be
$330,353.  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, subparts GGG and GGGa.

	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
through work practices, such as 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, and NSPS Subpart GGGa references NSPS Subpart VVa for
compliance.  Monthly monitoring of compressors and equipment in VOC
service under NSPS Subpart GGG shall take place as specified in NSPS
Subpart VV §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 part 60,
subpart VV or VVa.

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 additional records required by subpart GGGa have
been identified as additional information needed by Agency inspectors to
ensure compliance.  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 and subpart GGGa.  

	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 followed
publication of the proposed amendments in the Federal Register.  Several
comments were received on the proposed standards and burden estimates. 
In consideration of these comments, several changes in the standards and
compliance requirements were made that affected the burden estimates.

	3(c)  Consultations

	During development of the proposed amendments, EPA held meetings and
conference calls in which representatives of petroleum refining
companies and their trade associations (National Petroleum Refiners
Association and American Petroleum Institute) were provided an
opportunity to comment on the burden associated with the proposed
amendments.  

	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 GGGa 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) Code 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 or subpart GGGa.  These requirements are
summarized in the following tables.

	A source must make the following notifications and reports:

Notifications for 40 CFR Part 60, Subparts GGG and GGGa	Citation for
subpart GGG	Citation for subpart GGGa

Construction/reconstruction	60.7(a)(1)	60.7(a)(1)

Anticipated startup	60.7(a)(2)	60.7(a)(2)

Actual startup	60.7(a)(3)	60.7(a)(3)

Physical or operational change	60.7(a)(4)	60.7(a)(4)

Initial performance test	60.8(d)	60.8(d)

Alternative standard selected	60.487(d)	60.487a(d)



Reports for 40 CFR Part 60, Subparts GGG and GGGa	Citation for subpart
GGG	Citation for subpart GGGa

Initial performance test results	60.8(a)	60.8(a)

Comply with the provisions of 60.487	60.592(e)	60.592a(e)

Semiannual reports	60.486, 60.487(a) through (c)	60.486a, 60.487a(a)
through (c)

Performance test 	60.8, 60.487(e)	60.8, 60.487a(e)



	A source must keep the following records:

Recordkeeping for 40 CFR Part 60, Subparts GGG and GGGa	Citation for
subpart GGG	Citation for subpart GGGa

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

Comply with the provisions of 60.486 or 60.486a	60.592(e)	60.592a(e)

The date and instrument reading of each monitored component must be
recorded 	N/A	60.486a(a)

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

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

Equipment identification numbers and designations, and dates of
performance tests 	60.486(e)	60.486(e)(1) through (5)

Dates and results of weekly visual inspections	N/A	60.486a(e)(6)

Information related to instrument calibrations and drift checks	N/A
60.486a(e)(7)

Information pertaining to valves and pumps that are designated as unsafe
to monitor or difficult to monitor	60.486(f)	60.486a(f)

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

Design criteria and any changes	60.486(h)	60.486a(h)

Records for use in determining exemptions	60.486(i)	60.486a(i)

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



	Records are required to be retained for 2 years.

ii.  Respondent Activities

	The respondent activities required by 40 CFR part 60, subparts GGG and
GGGa are identified in the following table:

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, subparts GGG and GGGa:

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 Air Facility System



	5(b)  Collection Methodology and Management

	The required data and reports can be evaluated onsite by conducting a
partial compliance evaluation, full compliance evaluation or inspection,
or through offsite review of compliance monitoring records and reports. 
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 the Air Facility
System (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 over 125,000 industrial and
government-owned facilities.  EPA uses the AFS for tracking air
pollution compliance and enforcement by local and State regulatory
agencies, and 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

	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 and in Table
4:  Annual burden of reporting and recordkeeping requirements as a
result of NSPS Subpart GGGa.

6.  Estimating the Burden and Cost of the Collection

	Tables 2 and 4 document the computation of individual burdens for the
recordkeeping and reporting requirements applicable to the industry for
the Subparts 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.  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

	  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 recordkeeping time for each day’s worth of monitoring for
both subpart GGG and subpart GGGa is 0.3 hours and that monitoring is
done 365 days a year.  An additional 0.10 hours per day are estimated
for a typical refinery to complete the new recordkeeping tasks required
by subpart GGGa.  These tasks include collecting and maintaining records
of all instrument readings (3 minutes per day), daily instrument
calibrations and drift checks (3 minutes per day), and weekly pump
inspections (15 minutes per week).  Instrument readings are assumed to
be collected electronically; thus, the additional time is for
downloading additional data and organizing it for storage.  Smaller
facilities may record instrument readings manually.  For a facility with
a typical process, an average of 0.013 hours per day was estimated to
prepare and print recordkeeping forms and to manually record the
instrument readings on the forms.  This includes 2 hr/yr to prepare and
print recordkeeping forms and 10 seconds to record each reading for 9
pumps monitored monthly and 452 valves monitored semiannually. The time
to prepare reports is estimated to be the same under both subparts
because the information in the new records must be maintained on-site,
but it does not have to be reported.

The average annual burden to industry over the three years from these
recordkeeping and reporting requirements is estimated at 6,495
person-hours for subpart GGG and 4,216 person-hours for subpart GGGa. 
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 $80.41 per hour for technical, $120.92 per
hour for managerial and $36.67 for clerical.  These rates are from the
United States Department of Commerce Bureau of Labor Statistics, “May
2006 National Industry-specific Occupational Employment and Wage
Estimates; NAICS 324000 – Petroleum and Coal Products
Manufacturing.”  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 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 or O&M costs
associated with this standard.

		(iii)  Capital/Start-up vs. Operation 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 $17,138 for subpart GGG (from Table 1) and $25,975 for
subpart GGGa (from Table 3).  This cost is based on a combination of
technical hours (GS 12 Step 1 multiplied by a 1.6 benefits
multiplication factor to account for government overhead expenses, for a
total of $42.45/hr), managerial hours (GS-13 Step 5 multiplied by 1.6
for a total of $57.20/hr), and clerical hours (GS-6 Step 3 multiplied by
1.6 for a total of $22.96/hr).  The wage rates are from the 2006 General
Schedule from the Office of Personnel Management.  Details of the
analysis appear in Table 1: Average annual EPA resource requirements
resulting from NSPS Subpart GGG and Table 3: Average annual EPA resource
requirements resulting from NSPS Subpart GGGa. 

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

Respondent Universe 1 (Subpart GGG):

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

No. of Existing Sources	(B)

No. of Reports for Existing Sources	(C)

Total Annual Responses (AxB)

First year	45	2	90

Second year	45	2	90

Third year	45	2	90



	The number of total respondents in each year is 45.  The number
represents the number of existing sources averaged over the three-year
period. 

	

	The number of Total Annual Responses in each year is 90.  The total
annual labor costs are $508,970.  The number of burden hours on which
this estimate is based  is 6,495.  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.

Respondent Universe 2 (Subpart GGGa):

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

No. of New Sources/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 	10	4	0	2	40

Second year 	10	4	10	2	60

Third year 	10	4	20	2	80



Each year 10 new plants are subject to initial notification
requirements.  In addition, in any given year, all of the new facilities
from preceding years are subject to semiannual reporting requirements. 
Thus, an average of 20 facilities per year are subject to subpart GGGa
over the three-year period.  

	

	The average number of Total Annual Responses per year is 60.  The total
annual labor costs are $330,353.  The number of burden hours on which
this estimate is based is 4,216.  Details upon which this estimate is
based appear in Table 4: Annual burden of reporting and recordkeeping
requirements as a result of NSPS Subpart GGGa.

	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 (Tables 1, 2, 3, and 4).

	6(f)  Reasons for Change in Burden

	The increase in burden cost from the most recently approved ICR is due
to three reasons.  First, the new standards in subpart GGGa require the
same recordkeeping and reporting tasks as in subpart GGG as well as some
additional recordkeeping requirements.  Second, a higher number of new
sources are subject to the new subpart GGGa than would have been subject
to subpart GGG in the absence of the new standards.  This is because
many refineries already have process units that are subject to subpart
GGG.  Construction, reconstruction, or modification of another process
unit at these facilities would not increase the number of new facilities
subject to subpart GGG, but it does increase the number of new sources
subject to subpart GGGa.  Third, the revised analysis for this ICR
includes time for management and clerical workers as well as technical
staff.

	6(g)  Burden Statement

	The annual public reporting and recordkeeping burden for this
collection of information is estimated to average 72 hours per response
for subpart GGG and 70 hours per response for subpart GGGa.  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 

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  Technical Hours/ Yearb
(F) EPA Managerial Hours/Year 

(E x 0.05)	(G) EPA Clerical Hours/Year

(E x 0.10)

Initial Performance Tests (New Plants)	24	1	24	0	0	0	0

Repeat Performance Testsc (New Plants)	24	0.2	4.8	0	0	0	0

Report Review (New Plants)







	Notification of construction	2	1	2	0	0	0	0

Notification of anticipated startup	0.5	1	0.5	0	0	0	0

Notification of actual startup	0.5	1	0.5	0	0	0	0

Notification of initial test	0.5	1.2	0.6	0	0	0	0

Review test results	8	1.2	9.6	0	0	0	0

Report Review (Existing Plants)







	Emission Reports	4	2	8	45	360	18	36

Total Annual Hours



	360	18	36

Travel Expenses = (1 person x 0 plants/year x 3 days/plant x $50 per
diem) + ($250 round trip/plant x 2 plants/year) = $0/year

Salaryd =  (360 hours/year x $42.45/hour) + (18 hours/year x
$57.20/hour) + (36 hours/year x $22.96/hour) = $17,138/year

Total Annual Cost = $0 + $17,138 = $17,138

a  C = A x B

b  E = C x D

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

d  Estimate is based on a combination of technical hours (GS 12 Step 1
multiplied by a 1.6 benefits multiplication factor to account for
government overhead expenses, for a total of $42.45), managerial hours
(GS-13 Step 5 multiplied by 1.6 for a total of $57.20), and clerical
hours (GS-6 Step 3 multiplied by 1.6 for a total of $22.96).   Wages are
from the 2006 General Schedule from the Office of Personnel Management

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

	(A)  Hours per Occur-rence	(B)  Occurrences/ Respondent/Year	(C) 
Hours/ Respondent/Year

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

(C x D)	(F) Managerial Hours/Year (E x 0.05)	(G) Clerical Hours/Year (E
x 0.10)	(H)  Cost/ Year

1. APPLICATIONS (Not Applicable)









2. SURVEY AND STUDIES (Not Applicable)









3. REPORT REQUIREMENTS









A. Read Instructions	1	1	1	0	0	0	0	0 

B. Required Activities









Initial performance test	24	1	24	0	0	0	0	0 

Repeat performance test	24	1	24	0 b	0	0	0	0 

C. Create Information (Included in 3B)









D. Gather Existing Information (Included in 3E)









E. Write Report









Notification of construction or reconstruction	2	1	2	0	0	0	0	0 

Notification of anticipated startup	2	1	2	0	0	0	0	0 

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

Notification of initial performance test	2	1	2	0	0	0	0	0 

Report of performance test (Included in 3B)









Semiannual work practice reports	8	2	16	45 c	720	36	72	64,889

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 e	0.3	365 d	109.5	45 c	4,928	246	493
444,081

F. Train Personnel (Not Applicable)









G. Audits (Not Applicable)









5. TOTAL ANNUAL BURDEN



	5,648	282	565	$508,970

a  Only existing facilities because all new sources will be subject to
subpart GGGa.

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

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

d  Assume that average number of affected facilities over the next three
years is equal to the current number of facilities (45) because affected
facilities after November 7, 2006 will be subject to subpart GGGa
instead of subpart GGG.

e  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 recordkeeping time for each day’s worth of monitoring is
0.3 hours and that monitoring is done 365 days per year.

TABLE 3: AVERAGE ANNUAL EPA RESOURCE REQUIREMENTS RESULTING FROM NSPS
SUBPART GGGa.

Activity	(A)  EPA Hours/ Occurrence	(B)  Occurrences/ Plant/Year	(C) 
EPA Hours/ Plant/Yeara	(D)  Plants/Year	(E)  EPA Technical Hours/ Yearb
(F) EPA Managerial Hours/Year	(G) EPA Clerical Hours/Year

Initial Performance Tests (New Plants)	24	1	24	10	240	12	24

Repeat Performance Testsc (New Plants)	24	0.2	4.8	2c	9.6	0.48	1

Report Review (New Plants)







	Notification of construction	2	1	2	10	20	1	2

Notification of anticipated startup	0.5	1	0.5	10	5	0.25	0.5

Notification of actual startup	0.5	1	0.5	10	5	0.25	0.5

Notification of initial test	0.5	1.2	0.6	10	6	0.3	0.6

Review test results	8	1.2	9.6	10	96	4.8	9.6

Report Review (Existing Plants)







	Emission Reports	4	2	8	10	80	4	8

Total Annual Hours



	461.6	23.1	46.2

Travel Expenses = (1 person x 10 plants/year x 3 days/plant x $50 per
diem) + ($250 round trip/plant x 10 plants/year) = $4,000/year

Salaryd = (461.6 hours/year x $42.45/hour) + (23.1 hours/year x
$57.20/hour) + (46.2 hours/year x $22.96/hour) = $21,975/year

a  C = A x B

b  E = C x D

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

d  Estimate is based on a combination of technical hours (GS-12 Step 1
multiplied by a 1.6 benefits multiplication factor to account for
government overhead expenses for a total of $42.45), managerial hours
(GS-13 Step 5 multiplied by 1.6 for a total of $57.20), and clerical
hours (GS-6 Step 3 multiplied by 1.6 for a total of $22.96).   Wages are
from the 2006 General Schedule from the Office of Personnel Management.

TABLE 4: ANNUAL BURDEN OF REPORTING AND RECORDING REQUIREMENTS AS A
RESULT OF NSPS SUBPART GGGaa

	(A)  Hours per Occur-rence	(B)  Occurrences/ Respondent/Year	(C) 
Hours/ Respondent/Year

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

(C x D)	(F) Managerial Hours/Year (E x 0.05)	(G) Clerical Hours/Year (E
x 0.10)	(F)  Cost/ Year

1. APPLICATIONS (Not Applicable)









2. SURVEY AND STUDIES (Not Applicable)









3. REPORT REQUIREMENTS









A. Read Instructions	1	1	1	10	10	0.5	1	901

B. Required Activities









Initial performance test	24	1	24	10	240	12	24	21,630

Repeat performance test	24	1	24	2 b	48	2.4	4.8	4,326 

C. Create Information (Included in 3B)









D. Gather Existing Information (Included in 3E)









E. Write Report









Notification of construction or reconstruction	2	1	2	10	20	1	2	1,802

Notification of anticipated startup	2	1	2	10	20	1	2	1,802

Notification of actual startup	2	1	2	10	20	1	2	1,802

Notification of initial performance test	2	1	2	10	20	1	2	1,802

Report of performance test (Included in 3B)









Semiannual work practice reports	8	2	16	20 d	320	16	32	28,839

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 at large refiners e	0.40	365 c	148	17.4
d,f	2,571	129	257	231,700

Records of operating parameters for small refiners	0.42g	365 c	153	2.6
d,f	397	20	40	35,747

F. Train Personnel (Not Applicable)









G. Audits (Not Applicable)









5. TOTAL ANNUAL BURDEN



	3,666	183	367	$330,353

a  Estimating that there are approximately 30 refineries (respondents)
which become subject over a 3-year period.  The number of new sources
per year equals 30/3 = 10.

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

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

d  Assume that average number of affected facilities over the next three
years is estimated by the number of affected facilities in the second
year (10 new and 10 existing).

e  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.  An additional 0.10 hours per
day are needed to complete the tasks required by the new standards.

f  Assume 26 percent of the new process units per year are at small
refineries and half of those use manual recordkeeping of instrument
readings (20 x 0.26 x 0.5 = 2.6).

g  Estimated that most facilities need an additional 0.10 hours per day
to complete the tasks required by the new standards.  Estimated that
0.113 hours per day are needed for small refineries with manual
recordkeeping of instrument readings.

	

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