SUPPORTING STATEMENT

THE CONSOLIDATED FEDERAL AIR RULE FOR SOCMI

(WITH NEW NSPS SUBPART VVa)

Part A of the Supporting Statement

1.  Identification of the Information Collection

1(a)  Title of the Information Collection

“The Consolidated Federal Air Rule for SOCMI (with New NSPS Subpart
VVa)”

1(b)  Short Characterization/Abstract

This information collection request (ICR) is for the Consolidated
Federal Air Rule (CAR) for the Synthetic Organic Chemical Industry
(SOCMI) and its referencing subparts.  The burden estimates in this ICR
reflect changes to subpart VV and new standards in subpart VVa; other
burden estimates are consistent with the most recently approved ICR for
the CAR.  The U.S. Environmental Protection Agency (EPA) will use this
information to ensure compliance with the provisions in the CAR and its
referencing subparts.

All existing sources must be in compliance with the requirements of the
CAR and/or its referencing subparts within three years of the effective
date (i.e., promulgation date) of the appropriate standard for the
affected source.  All new sources must be in compliance with the
requirements of the CAR and/or its referencing subparts upon startup or
the promulgation date of standards for an affected source, whichever is
later.  Compliance is assumed through initial performance testing or
design analysis, as appropriate, and ongoing compliance is demonstrated
through parametric monitoring.  Types of parameters monitored are
incinerator temperature, scrubber flow rate, carbon adsorber
regeneration frequency, as well as others.  The appropriate parameter to
monitor depends on the type of control device with the owner or operator
chooses to comply.

 

On December 14, 2000, the CAR was promulgated under 40 CFR part 65.  The
CAR is an optional alternative compliance approach for plant sites that
must comply with existing subparts in the Code of Federal Regulations
(CFR).  The CAR is a consolidation of major portions of 14 different
New Source Performance Standards (NSPS) and National Emission Standards
for Hazardous Air Pollutants (NESHAP) pertaining to storage vessels,
process vents, transfer racks, and equipment leaks, and the general
provisions for the three applicable parts (40 CFR parts 60, 61, and
63).  These subparts from 40 CFR parts 60, 61, and 63 are referred to
as “referencing subparts” because they have been amended to refer to
the CAR as a compliance alternative.  The referencing subparts include
40 CFR part 60, subparts Ka, Kb, VV, DDD, III, NNN and RRR; 40 CFR part
61, subparts BB, Y, and V; 40 CFR part 63, subparts F, G, H, and I.		

Compliance with the CAR is a voluntary alternative; sources may
continue to comply with existing applicable rules or may choose to
comply with the consolidated rule.  When preparing renewals for the CAR,
or the referencing subparts, estimates are made of the percentage of
existing sources that will opt to comply with the CAR in lieu of the
referencing subparts.  Because the CAR is designed for, although not
limited to, SOCMI facilities, the number of facilities opting to comply
with the CAR is based on the estimated number of SOCMI facilities.  It
is estimated that 25 percent of non-Hazardous Organic NESHAP (HON)
sources will opt to comply with the CAR if the per-source burden of
complying with the CAR is less than the per-source burden of complying
with the referencing subpart.  For those referencing subparts for which
the per-source burden of complying with the CAR is higher than the
per-source burden of complying with the referencing subpart (subparts
Ka, Kb, Y, VV, III, NNN, RRR, and DDD), it is estimated that 5 percent
of sources will opt to comply with the CAR.  It is also estimated that
25 percent of HON sources will opt to comply with the CAR.  It is
assumed that all new sources will initially comply with the appropriate
referencing subpart.  For the three years covered by this ICR, it is
assumed that none of the sources subject to new subpart VVa will comply
with the CAR.

It is estimated that the consolidated collection will involve 3,305
respondents with 9,953 annual responses and respondent labor costs of
$145,725,751.  The total Agency burden is estimated to be 24,541 hours
per year at a cost of $1,016,007.  Total capital costs will be
$3,373,000 per year, and total capital and operation and maintenance
(O&M) costs will be $95,329,000 per year.

It is estimated that the information collection for the new subpart VVa
will involve 76 respondents with 244 annual responses and respondent
labor costs of $527,104.  The total Agency burden for subpart VVa is
estimated to be 614 hours per year at a cost of $25,438.  Total capital
costs will be $4,200 per year, and total capital and O&M costs will be
$4,200 per year.

The CAR (Consolidated Air Rule)

In general, the NSPS, NESHAP, CAR, and maximum achievable control
technology (MACT) regulations require initial notifications including
one-time notifications of initial startup, applicability, and initial
compliance status; performance tests, periodic monitoring,
recordkeeping, and reporting.  Periodic reports are required
semiannually, and a startup, shutdown, and malfunction plan must be
submitted and updated as needed.  In addition, respondents taking
advantage of various provisions for waivers, approval of alternative
methods, and changes in submittal schedules would be required to submit
requests or applications.  This information is being collected to assure
compliance with 40 CFR part 65.

NSPS subpart Ka: Storage Vessels for Petroleum Liquids

The NSPS for subpart Ka were proposed on May 18, 1978 and promulgated on
April 4, 1980.  These standards apply to storage vessels of petroleum
liquids that have a storage capacity greater than 151,416 (40,000
gallons), and for which construction, reconstruction or modification
commenced after May 18, 1978 and prior to July 23, 1984.  There is a de
minimis exemption located at §60.110a(b).  The regulated pollutants are
volatile organic compounds (VOC).  The universe of sources subject to
NSPS subpart Ka is closed.  Any new sources will be subject to NSPS
subpart Kb, the most recent VOC standard applicable to storage vessels. 
This information is being collected to assure compliance with 40 CFR
part 60, subpart Ka.

NSPS subpart Kb: Volatile Organic Liquid (VOL) Storage Vessels

The NSPS for subpart Kb were proposed on July 23, 1984 and promulgated
on April 8, 1987.  These standards apply to each storage vessel with a
capacity greater than or equal to 40 cubic meters that is used to store
volatile organic liquids, for which construction, reconstruction or
modification commenced after July 23, 1984.  There are exemptions for
specific storage vessels listed in §§60.110b(b), 60.110b(c), and
60.110b(d).  The standards include visual inspection, leak detection,
and repair for equipment configurations including fixed and floating
roofs.  The regulated pollutants are VOC.  This information is being
collected to assure compliance with 40 CFR part 60, subpart Kb.

NSPS subpart VV: Equipment Leaks of VOC in the SOCMI Industry

The NSPS for Emissions of VOC from Equipment Leaks in the SOCMI Industry
were proposed on January 5, 1981.  These standards were promulgated on
October 18, 1983.  They apply to specific pieces of equipment contained
within a process unit in the synthetic organic chemicals manufacturing
industry which was constructed, modified or reconstructed after the date
of proposal and on or before November 7, 2006, and which produce as an
intermediate or final product, one or more of the chemicals listed in
§60.489.  These include pumps in light liquid service, compressors,
pressure relief devices in gas/vapor service, sampling connection
systems, open-ended valves or lines, valves in gas/vapor service and
light liquid service, pumps and valves in heavy liquid service, pressure
relief devices in light liquid or heavy liquid service and flanges and
other connectors.  The regulated pollutants are VOC.  The universe of
sources subject to NSPS subpart VV is closed.  Any new sources will be
subject to NSPS subpart VVa, the most recent VOC standard applicable to
equipment leaks.  This information is being collected to assure
compliance with 40 CFR part 60, subpart VV.

NSPS subpart VVa: Equipment Leaks of VOC in the SOCMI Industry

NSPS subpart VVa is a new standard that applies to equipment contained
within a SOCMI process unit that is constructed, modified, or
reconstructed after November 7, 2006.  The regulated pollutants are VOC.
 This information is being collected to assure compliance with 40 CFR
part 60, subpart VVa.

NSPS subpart DDD: VOC Emissions from the Polymer Manufacturing Industry

The NSPS for the polymer manufacturing industry were proposed on
September 30, 1987, and January 10, 1989, and promulgated on December
11, 1990.  These standards apply to facilities involved in the
manufacture of polypropylene, polystyrene, or poly(ethylene
terephthalate) commencing construction, modification or reconstruction
after the date of proposal or after January 10, 1989, depending on the
process section.  The affected facilities include: 1) For polypropylene
and polyethylene manufacturing: each raw material preparation section,
each polymerization reaction section, each material recovery section,
each product finishing section, and each product storage; 2) For
polystyrene manufacturing processes: each material recovery section; and
3) For polyethylene (terephthalate) manufacturing: each polymerization
reaction section.  For equipment leaks, the affected facilities are each
group of fugitive emissions equipment within any process unit.  The
regulated pollutants are VOC.  This information is being collected to
assure compliance with 40 CFR part 60, subpart DDD.

NSPS subpart III: VOC Emissions from SOCMI Air Oxidation Unit Processes

The NSPS for the SOCMI Air Oxidation Unit Processes were proposed on
October 21, 1983, and promulgated on June 29, 1990.  These standards
apply to the following facilities for which construction, modification
or reconstruction is commenced after the date of proposal: 1) Each air
oxidation reactor not discharging its vent stream into a recovery
device; 2) Each combination of an air oxidation reactor and the recovery
system into which its vent stream is discharged; and 3) Each combination
of two or more air oxidation reactors and the common recovery system
into which their vent streams are discharged.  The standard applies to
the affected facility which produces one or more of the chemicals listed
in §60.617 as a product, co-product, byproduct or intermediate.  The
regulated pollutants are VOC.  This information is being collected to
assure compliance with 40 CFR part 60, subpart III.

NSPS subpart NNN: VOC Emissions from SOCMI Distillation Operations

The NSPS for the SOCMI Distillation Operations were proposed on December
30, 1983 and promulgated on June 29, 1990.  These standards apply to the
following facilities for which construction, modification or
reconstruction is commenced after the date of proposal: 1) Each
distillation unit not discharging its vent stream into a recovery
device; 2) Each combination of a distillation unit and the recovery
system into which its vent stream is discharged; and 3) Each combination
of two or more distillation units and the common recovery system into
which their vent streams are discharged.  The standard applies to
affected facilities producing one or more of the chemicals listed in
§60.667 as a product, co-product, by-product, or intermediate.  The
regulated pollutants are VOC.  This information is being collected to
assure compliance with 40 CFR part 60, subparat NNN.

NSPS subpart RRR: VOC Emissions from SOCMI Reactor Processes

The NSPS for the synthetic organic chemical manufacturing industry
(SOCMI) Reactor Processes were proposed on June 29, 1990, and
promulgated on August 31, 1993.  These standards apply to affected
facilities commencing construction, modification or reconstruction after
the date of proposal: (1) Each reactor process not discharging its vent
stream into a recovery system; (2) Each combination of a reactor
processes and the recovery system into which its vent stream is
discharged; (3) Each combination of two or more reactor processes and
the common recovery system into which their vent streams are discharged.
 The standard applies to affected facilities producing one or more of
the chemicals listed in §60.707 as a product, co-product, by-product,
or intermediate.  The regulated pollutants are VOC.  This information is
being collected to assure compliance with 40 CFR part 60, subpart RRR.

NESHAP subpart BB: Benzene Emissions from Benzene Transfer Operations

The National Emission Standards for Benzene Emissions from Benzene
Transfer Operations were proposed on September 14, 1989, and promulgated
on March 7, 1990.  The affected facility to which this subpart applies
is the total of all loading racks handling a liquid containing 70
weight-percent or more benzene, at which benzene is loaded into tank
trucks, railcars, or marine vessels at each benzene production facility
and each bulk terminal.  However, specifically exempted from this
regulation are loading racks at which only the following are loaded:
Benzene-laden waste (covered under subpart FF of part 61), gasoline,
crude oil, natural gas liquids, petroleum distillates (i.e., fuel oil,
diesel, or kerosene), or benzene-laden liquid from coke by-product
recovery plants.  In addition, any affected facility which loads only
liquid containing less than 70 weight-percent benzene or whose annual
benzene loading is less than 1.3 million liters of 70 weight-percent or
more benzene is exempt from the control requirements except for the
recordkeeping and reporting requirements in §61.305(i).  Marine vessels
were given a one-year industry wide waiver of compliance, which was
later extended to July 23, 1991, in order to allow for concurrent
compliance with United States Coast Guard regulations.  The regulated
pollutant is benzene.  This information is being collected to assure
compliance with 40 CFR part 61, subpart BB.

NESHAP subpart Y: Benzene Emissions from Benzene Storage Vessels 

The NESHAP for Benzene Emissions from Storage Vessels were proposed in
1980 and re-promulgated in 1989 (54 FR 38077) as 40 CFR part 61, subpart
Y.  Entities affected by this action are those owners and operators of
benzene storage vessels that store benzene having a specific gravity
within the range of specific gravities as specified in ASTM D 4734-98
for Refined Benzene-545.  Storage vessels with a design storage capacity
less than 38 cubic meters (10,000 gallons) are exempt from the
provisions of the subpart.  Similarly, storage vessels used for storing
benzene at coke by-product facilities or vessels permanently attached to
motor vehicles such as trucks, rail cars, barges, or ships or pressure
vessels designed to operate in excess of 204.9 kPa and without emissions
to the atmosphere are also exempt from this subpart.  The regulated
pollutant is benzene.  This information is being collected to assure
compliance with 40 CFR part 61, subpart Y.

NESHAP subpart V: National Emission Standard for Equipment Leaks
(Fugitive Emission Sources)

Affected facilities include the following sources that are intended to
operate in volatile hazardous air pollutant (HAP) service: pumps,
compressors, pressure relief devices, sampling connection systems,
open-ended valves or lines, valves, flanges and other connectors,
product accumulator vessels, and control devices or systems.  The
standards for this subpart are leak detection and repair (LDAR).  The
regulated pollutants are volatile HAPs.  This information is being
collected to assure compliance with 40 CFR part 61, subpart V.

NESHAP subparts F, G, H and I: The HON

The MACT standards for the HON were proposed on December 31, 1992 and
promulgated on April 22, 1994.  These standards apply to chemical
manufacturing process units (CMPU’s) in the SOCMI industries, which
manufacture as a primary product one or more of the chemicals listed in
Table 1 of 40 CFR part 63, subpart F; use as a reactant or manufacture
as a product, by-product, or co-product, one or more of the organic HAPs
listed in Table 2 of subpart F; and are located at a plant site that is
a major source as defined in section 112(a) of the Act.  Additionally,
styrene-butadiene rubber production, pesticide production, polybutadiene
production, chlorinated hydrocarbon use in the production of chemicals,
pharmaceutical production, and miscellaneous butadiene use are subject
to the negotiated regulations affecting equipment leaks promulgated
under subpart I.  The emission points include transfer racks, storage
tanks, wastewater systems, process vents and equipment leaks.  The
regulations apply to existing sources as well as new sources commencing
construction or reconstruction after the date of proposal.  Hazardous
air pollutants are the pollutants regulated under these subparts. This
information is being collected to assure compliance with 40 CFR part 63,
subparts F, G, H and I.

2.  Need for and Use of the Collection

2(a)  Need/Authority for the Collection

The Clean Air Act (CAA or 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 NSPS under section 111 of the Act; the NESHAP,
which includes the original NESHAP standards and the more recent 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 duplication in the collection and reporting
of information.  If the subject standards have not been delegated, the
information is sent directly to the appropriate EPA Regional office. 
Otherwise, the information is sent directly to the delegated State or
local agency.  If a State or local agency has adopted 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

A public review and comment period occurred after proposal of the
amendments to the Standards of Performance for equipment leaks of VOC in
the SOCMI (40 CFR part 60, subpart VV).

3(c)  Consultations

The EPA provided a 90-day public comment period after proposal of the
amendments to the standards of performance for equipment leaks of VOC in
the SOCMI.  All affected parties were given the opportunity to comment
on the proposed amendments during this period.  Several comments were
received on the standards and compliance procedures.  Changes were made
based on these comments.

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.  Representatives of the American Chemistry Council
declined invitations to participate in development of the proposed
amendments.

Interested parties were provided an opportunity to comment on the burden
associated with the CAR and other referencing subparts when the CAR was
being developed and in comments submitted in response to the first
Federal Register notice announcing renewal of this ICR.  Since the
amendments to 40 CFR part 60, subpart VV and the new standards at
subpart VVa do not affect the burden estimates for the CAR and other
referencing subparts, no changes have been made to the burden estimates
for those rules relative to the estimates in the last approved ICR for
the CAR.  Thus, the only consultation with industry being conducted at
this time involves burden estimates for amendments to subpart VV and the
new standards in subpart VVa.

3(d)  Effects of Less Frequent Collection

The effect of less frequent collection would be a decrease in the margin
of assurance that facilities are achieving the emission reductions
mandated by the CAA through the promulgation of the applicable
regulations.  In addition, the likelihood of detecting the poor
operation and maintenance of control equipment decreases, and the
detection of noncompliance becomes problematic.

3(e)  General Guidelines

Neither the reporting nor recordkeeping requirements violate the
regulations established by Office of Management and Budget (OMB) at 5
CFR 1320.5.  However, most NESHAP and a few NSPS 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.

The retention of records for five years allows EPA to establish the
compliance history of the respondent for purposes of determining the
appropriate level of enforcement action.  Historically, EPA notes that
the most flagrant violations have extended beyond a five-year period. 
If records are retained for less than five years, EPA would be deterred
from pursuing the most flagrant violations due to the destruction of
records documenting noncompliance.

3(f)  Confidentiality

Any information submitted to the Agency for which a claim of
confidentiality is made will be safeguarded according to the Agency
policies set forth in Title 40, chapter 1, part 2, subpart B -
Confidentiality of Business Information (see 40 CFR 2; 41 FR 36902,
September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR
42251, September 20, 1978; 44 FR 17674, March 23, 1979).

3(g)  Sensitive Questions

The recordkeeping and reporting requirements do not contain sensitive
questions.

4.  The Respondents and the Information Requested

4(a)  Respondents/SIC Codes

The Standard Industrial Classification(SIC) codes and corresponding
North American Industry Classification System (NAICS) for the
respondents are listed below.

 

SIC Code	

NAICS Code



2821	

325211



2824	

325222



2851	

32551



2865*	

325111, 325132, 325192



2869*	

32511, 325193, 325199



2899*	

32511, 325199



2911	

32411



2951	

324121



2952	

324122



2992	

324191



2999	

324199



4212	

562111, 562112, 562119, 48411, 48421, 48422



4213	

484121, 484122, 48421, 48423



4214	

48411, 48421, 48422



4215	

49211, 49221



4221	

49313



4222	

49312



4225	

49311, 53113



4226	

49312, 49311, 49319



4231	

48849



4412	

483111



4424	

483113



4432	

483113



4449	

483211



4481	

483112, 483114



4482	

483114, 483212



4489	

483212, 48721



4491	

48831, 48832



4492	

48833



4493	

71393



4499	

532411, 48831, 48833, 48839



4724	

56151



4725	

56152



4729	

488999, 561599



4731	

541614, 48851



4741	

532411, 48821



4783	

488991



4785	

48839, 48849



4789	

488999, 48711, 72231, 48821

*These SIC codes characterize respondents most likely to be subject to
the amendments to 40 CFR part 60, subpart VV and the new standards of
subpart VVa.

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, please see the applicability provisions in the standard.

4(b)  Information Requested

(i)  Data Items

Attachment A lists the recordkeeping and reporting requirements for the
CAR and the referencing subparts.

Electronic Reporting

At present, many respondents to CAA standards use monitoring equipment
that automatically records parameter data.  Although personnel at the
affected facility must evaluate the data, this internal automation has
significantly reduced the burden associated with monitoring and
recordkeeping at the plant site.

Also regulatory agencies, in cooperation with the respondents, continue
to create reporting systems to transmit data electronically.  However,
electronic reporting systems are still not widely used.  At this time,
it is estimated that approximately 20 percent of the respondents use
electronic reporting.

(ii)  Respondent Activities

The respondent activities required by the CAR and the referencing
subparts are identified in the following table.

Respondent Activities



Read instructions.



Install, calibrate, maintain, and operate CPMS for the appropriate
control device



Perform initial performance test and repeat performance tests if
necessary.



Write the notifications and reports listed in Attachment A



Enter information required to be recorded in Attachment A.



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.



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

5(a)  Agency Activities 

The Agency activities associated with the CAR are presented in Table 1,
and the Agency activities associated with the referencing subparts are
shown in Tables F-1 through F-12.  EPA conducts one or more of these
activities in connection with the acquisition, analysis, storage, and
distribution of the required information.

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 its
delegated authorities can edit, store, retrieve, and analyze the data.

5(c)  Small Entity Flexibility

Minimizing the information collection burden for all sizes of
organizations is a continuing effort on EPA’s part.  EPA has limited
recordkeeping and reporting to the minimum necessary to ensure and
verify compliance with the rule.  The new standards in subpart VVa
include additional recordkeeping and reporting requirements; experience
with enforcing the existing subpart VV has shown that additional data
are needed.  Some of the records required in subpart VVa that are not
required in subpart VV are already required in other equipment leak
rules.  For example, other rules already require records of the dates
and results of weekly visual inspections of pumps.  Other new
requirements are unique to subpart VVa, but the level of effort involved
is small.  Generating records of all instrument readings should add
minimal burden for most SOCMI facilities because identification of the
equipment monitored, the instrument reading, and the monitoring date
generally are collected electronically for all equipment while
monitoring; the only additional burden would be to download all of the
data rather than just the leaker data to storage, and to make sure that
the records include identification of the operator and monitoring
instrument.  The burden will be greater for small facilities that rely
on manual recording of instrument readings.  It was assumed that 10
percent of the SOCMI sources that become subject to subpart VVa use
manual recordkeeping procedures; for these facilities the additional
recordkeeping burden was estimated to be 3.5 hours per year (hr/yr). 
Records (and related reporting) of leaks identified as a result of the
new annual monitoring requirement for open-ended lines and the new
requirement for connector monitoring are needed to document compliance
with subpart VVa.  Another activity is to record information regarding
instrument calibrations and drift checks because this effort would apply
each day when instrument monitoring is conducted.  For a typical or
average process, monitoring should take no more than about 7 days during
months when valves must be monitored, less during other months.  The
recordkeeping level of effort per day, however, should be no more than a
few minutes.  Overall, EPA does not expect that small organic chemical
manufacturing businesses will experience adverse impacts related to the
cost of the reporting and recordkeeping requirements in the new
standards of subpart VVa.

5(d)  Collection Schedule

The specific frequency for each information collection activity within
this request is shown in Table 5 for the CAR and Tables G-1 through G-13
for the referencing subparts, respectively.

6.  Estimating the Burden and Cost of the Collection

Table 5 for the CAR and Tables G-1 through G-13 for the referencing
subparts document 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 respondent burden is summarized in Table 6 and detailed in Table 5
for the CAR and Tables G-1 through G-13 for the referencing subparts. 
The labor hours 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.  Changes from the previously approved ICR have been made for
subparts VV and VVa in Tables G-3 and G-13, respectively.

6(b)  Estimating Respondent Costs

(i)  Estimating Labor Costs 

 

This ICR uses the following labor rates: 

Managerial (General and Operations)	$125.87 ($59.94 + 110%)

Technical (Environmental Engineers)	$74.36 ($35.41 + 110%)

Clerical (Office Support Occupations)	$36.04 ($17.16 + 110%)

These rates are from the United States Department of Labor, Bureau of
Labor Statistics, May 2006 National Industry-Specific Occupational
Employment and Wage Estimates, NAICS 325000 Chemical Manufacturing
(http://www.bls.gov/oes/current/naics3_325000.htm)  The rates have been
increased by 110 percent to account for the benefit packages available
to those employed by private industry.

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

Because we assume that no new sources will opt to comply with the CAR at
startup over the next 3 years, there are no capital costs associated
with the CAR.  Facilities that comply with the CAR are assumed to have
already purchased any equipment needed to comply with the referencing
subpart.  Capital/Startup and O&M costs for the referencing subparts are
summarized in Table 6.  

Details of the capital/startup and O&M costs, as taken from the most
recently approved ICR for the CAR and referencing subparts, are detailed
in Appendix J.  The capital/startup and O&M costs to comply with subpart
VV are estimated to be $0 per year because it is assumed that facilities
that are already complying with subpart VV will not need to buy an
additional monitor, an no additional facilities will become subject to
subpart VV in the future.  The estimated capital/startup and O&M costs
for subpart VVa are $4,200 per year.  These costs are for an estimated 3
facilities that are assumed to construct new process units and that
would have to purchase a monitor because they would not also be subject
to other rules that require monitoring of equipment leaks.

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

The total capital/startup costs for this ICR are detailed in Appendix J
and summarized in Table 6 in column F.  The total O&M costs for this ICR
is the total of column E in Table 6.

6(c)  Estimating Agency Burden and Costs

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

The average annual Agency burden and cost during the three years of the
ICR is 24,541 hours and $1,016,007.  This is calculated in Table 2 for
the CAR and Attachments F-1 through F-12 for the referencing subparts,
and is summarized in Table 6.  See Table F-3 for the changes resulting
from the amendments to subpart VV and Table F-12 for the new standards
of subpart VVa.

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

Managerial	$57.20 (GS-13, Step 5, $35.75 x 1.6)

Technical	$42.45 (GS-12, Step 1, $26.53 x 1.6)

Clerical	$22.96 (GS-6, Step 3, $14.35 x 1.6)

These rates are from the Office of Personnel Management (OPM) “2006
General Schedule” which excludes locality rates of pay. 

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

Number of respondents is calculated in Table 5 for the CAR, and
Attachments G-1 through G-13 for the referencing subparts for the three
years covered by this ICR and summarized in Column (B) of Table 6.

A summary of the total annual labor cost may be found in Table 6.  A
detailed description of the Total Hours Requested may be found in Table
5 for the CAR, and Attachments G-1 through G-13 for the referencing
subparts.  See Table G-3 for the burden related to the amendments to
subpart VV and Table G-13 for the new standards of subpart VVa.

6(e)  Bottom Line Burden Hours and Cost Tables

The detailed bottom line burden hours and cost calculations for the
respondents and the Agency are summarized in Table 6 and detailed in
Tables 2 and 5 for the CAR, and Tables F-1 through F-12 and G-1 through
G-13 for the referencing subparts, respectively.

(i)  Respondent Tally

Details regarding the total hours requested and annual labor cost
estimates may be found in Table 5 for the CAR, and Tables F-1 through
F-12 and G-1 through G-13 for the referencing subparts, respectively. 
Furthermore, the overall annual public reporting and recordkeeping
burden for this collection of information is estimated to average 200
hours per response.  This is calculated by dividing the Respondent
Burden Hours in Table 6 by the Total Annual Responses in Table 6.  The
burden associated with the new subpart VVa is estimated to average 29
hours per response.

(ii)  The Agency Tally

The average annual Agency burden hours and cost over next three years is
24,541 hours at a cost of $1,016,007.  This is summarized in Table 6 and
detailed in Table 2 for the CAR and Tables F-1 through F-12 for the
referencing subparts.  This burden is a decrease of 3,453 hours from the
most recently approved ICR.  The overall decrease is a combination of an
estimated decrease in the number of sources subject to subpart VV, and
an estimated increase due to the new standards of subpart VVa.

6(f)  Reasons for Change in Burden

There is a decrease of 68,500 burden hours from the most recently
approved ICR due to adjustments.  These adjustments result from new
standards of NSPS subpart VVa (Table G-13), and revised estimates of the
number of sources subject to subpart VV (Table G-3).  The new standards
of NSPS subpart VVa require respondents to keep additional records for
leaks from open-ended lines and connectors, the results of weekly
inspections of pumps, daily calibrations and drift checks of the
monitoring instrument, and all instrument readings.  In addition,
semiannual reports must include information related to leaks from
open-ended lines and connectors.  The adjustments to the number of
sources are a result of analyses performed during development of the
amendments to Subpart VV and the new standards in subpart VVa.  Specific
changes to tables are described below:

Table 6 - Since this is a summary table, the appropriate entries were
changed according to the changes made to Tables F-3, F-12, G-3, and
G-13.

Table F-3 - The table was updated to provide a more realistic estimate
for the number of existing sources subject to these provisions, which
decreased the overall burden for this subpart.

Table F-12 - The table was added to include an estimate of the burden to
review reports required by the new NSPS subpart VVa.  The estimate
includes the same 2 hours to review semiannual reports that contain the
information required by subpart VV, plus an additional 0.45 hour for
Agency review of the additional information the must be submitted under
subpart VVa.  This estimate includes about 24 minutes to review
information about open-ended lines (which is monitored and reported
semi-annually) and about 3 minutes to review information about leaking
connectors in one report per year.

Table G-3 -  Table G-3 was updated to provide a more realistic estimate
for the number of existing sources subject to these provisions, which
decreased the overall burden for this subpart.

Table G-13 -  Table G-13 was added to detail the recordkeeping and
reporting requirements of the new standards of NSPS subpart VVa.  For 90
percent of the facilities, these requirements include the 80
hrs/occurrence to prepare the same records as required under subpart VV
plus an additional 9.5 hrs/occurrence to enter records of the additional
information required by subpart VVa.  It also includes the 4
hr/occurrence to prepare semiannual reports with the same information
required under subpart VV plus an additional 0.5 hr/occurrence to add
the additional information required by subpart VVa.  For the estimated
10 percent of facilities that manually record instrument readings, the
additional recordkeeping is estimated to be 15.2 hrs/occurrence.

The 9.5 hours per year of additional recordkeeping burden associated
with the new requirements in subpart VVa is estimated based on 30
minutes per year (min/yr) to record information about leaks and possibly
delay of repair for open-ended lines (15 minutes for each semiannual
monitoring event), 15 min/yr to record information about leaks for
connectors (assuming the one-quarter of all connectors that are
monitored during the year are all monitored in one semiannual period), 2
min/week to record the date and results of weekly visual inspections of
pumps, 2 min/day for 7 d/month to record instrument calibration and
drift check information, and 3 min/day for 7 d/month to record all of
the instrument readings.  The 7 days/month for instrument monitoring is
a maximum for a typical process with about 1,600 valves and pumps and
1,400 connectors; in months when valve monitoring is not required, the
number of monitoring days will be less.  It is assumed that connectors
are monitored every four years so that 350 are monitored each year.  For
the 10 percent of facilities that are small and manually record
instrument readings it was assumed that the process has 15 pumps
monitored monthly, 457 valves and 33 open-ended lines monitored twice
per year, and 731 connectors monitored once every 4 years; an extra 10
seconds is needed to record each instrument reading, and an additional 2
hours per year was estimated to prepare and print recordkeeping forms. 
The additional reporting burden assumes 10 min/report to document
information related to leaking open-ended lines (20 min/yr) and 10
min/yr to document information related to leaking connectors (i.e, every
other report).

6(g)  Burden Statement

The overall annual public reporting and recordkeeping burden for this
collection of information is estimated to average 200 hours per response
(29 hours per response for the new subpart VVa).  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
EPA-HQ-OAR-2006-0699, which is available for online viewing at 

www.regulations.gov, or in person viewing at the Enforcement and
Compliance 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 Enforcement and Compliance 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
2060-0443 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:  AGENCY ACTIVITIES

Performance Tests

-	 Initial

-	 Repeat

Review Reports

-	 Notification of Initial Startup

-	 Notification of Performance Test

-	 Initial Compliance Status

-	 Startup, Shutdown, Malfunction Plans

-	 Periodic Reports



TABLE 2:  ANNUAL BURDEN AND COST TO THE FEDERAL GOVERNMENT FOR THE CAR
PROVISIONS



Burden Item

(Reports to Review)	

Average Hours per Activity

(a)	

Number of Activities per Year

(b)	

Estimated Technical Hours per Yeara

(c)	

Estimated Managerial Hours per Yearb

(d)	

Estimated Clerical Hours per Yearc

(e)	

Annual Costd

(f)



1.	Initial Notification of Part 65 Applicability	

2	

27 e	

54	

3	

5	

$2,571



2.	Review Equipment Leak Monitoring	

5	

636 f	

3,180	

159	

318	

$151,387



3.	Review Periodic Reports	

4	

80 g	

320	

16	

32	

$15,234



TOTAL ANNUAL COST	

	

	

3,554	

178	

355	

$169,192



Total Annual Burden	

	

	

	

4,087	

	



a c = a x b

b Estimate managerial hours are 5 percent of technical hours.

c Estimate clerical hours are 10 percent of technical hours.

d Annual cost is the sum of costs for technical, managerial, and
clerical hours based on rates from the Office of Personnel Management
(OPM) “2006 General Schedule,” which excludes locality rates of pay.

Technical - $42.45 (GS-12, Step 1, $26.53 x 1.6)

Managerial - $57.20 (GS-13, Step 5, $35.75 x 1.6)

Clerical - $22.96 (GS-6, Step 3, $14.35 x 1.6)

e Estimate that all CAR sources must submit an Initial Notification of
Part 65 Applicability.  It is estimated that 1/3 of the sources will
submit an initial notification in each of the three years covered by
this ICR.  This equates to 27 per year (80/3) during each of the three
years following promulgation.

f Estimate that 318 equipment leak sources will comply with the CAR (240
from the HON, 59 from subpart VV and 19 from subpart V - see Table 4). 
Reports for equipment leaks will be submitted semiannually (318 x 2 =
636 per year).  See Attachment C for assumptions and further description
of activities. 

g Estimate that 25 percent of the 320 SOCMI facilities which equals 80
facilities will opt to comply with the CAR and must submit periodic
reports each year.

  

 

TABLE 3:  ESTIMATED NUMBER OF SOURCES SUBJECT TO REFERENCING SUBPARTS
THAT WILL OPT TO COMPLY WITH THE CAR

Referencing Subpart

(A)	

Estimated Number of Sources Complying with CARa, b (B)



Storage Vessels	





Ka	

458



Kb	

382



Y	

0



Transfer Racks	





BB	

0



Equipment Leaks	





V	

19



VV	

59



VVa	

0



Process Vents	





III	

1



NNN	

71



RRR	

8



DDD	

5 ADVANCE \u2 



HON F & G - Storage Vessels	

800



HON F & G - Transfer Racks	

320



HON H & I - Equipment Leaks	

240



HON F & G - Process Vents	

640

a Note that the estimate is on a per-source basis, rather than on a
facility basis and, therefore, correlates to (as described in the
footnote to the appropriate Table), but does not match, the facility
entries in the referencing subpart burden tables in Tables F-1 through
F-12 and G-1 through G-13.  For the purpose of this information
collection request, a source is defined as:

(	  one storage vessel (subparts Ka, Kb, Y, and G);

(	  one process vent (subparts DDD, III, NNN, RRR, and G);

(	  the collection of subject equipment for one process unit (subparts
VV, VVa, V, and H & I); or

(	  one transfer rack (subparts BB and G).

b From the most recently approved ICR.

 

TABLE 4: BASIS FOR ANNUAL RESPONDENT BURDEN OF REPORTING AND
RECORDKEEPING FOR THE CAR 

Burden Item	

Annual Burden in Technical Hours

	

Process Vents	

Storage Vessels	

Transfer Racks	

Equipment Leaks	

Inventory	

Total ADVANCE \u2 d ADVANCE \d2 







With Connectors	

Without Connectors ADVANCE \u2 a ADVANCE \d2 



	

per source ADVANCE \u2 b ADVANCE \d2 	

total ADVANCE \u2 c ADVANCE \d2 	

per source ADVANCE \u2 b ADVANCE \d2 	

total ADVANCE \u2 c ADVANCE \d2 	

per source ADVANCE \u2 b ADVANCE \d2 	

total ADVANCE \u2 c ADVANCE \d2 	

per source ADVANCE \u2 b ADVANCE \d2 	

total ADVANCE \u2 c ADVANCE \d2 	

per source ADVANCE \u2 b ADVANCE \d2 	

total ADVANCE \u2 c ADVANCE \d2 	

per source ADVANCE \u2 b ADVANCE \d2 	

total ADVANCE \u2 c ADVANCE \d2 

	

.	Read Rule and Instructions

	

2.9	

2,103	

1.1	

1,804	

1.1	

352	

2.5	

600	

1.0	

78	

1.8	

144	

5,081



.	Plan Activities

	

2.1	

1,523	

1.7	

2,788	

0.85	

272	

0.57	

137	

0.23	

18	

4.5	

360	

5,097



.	Training

	

1.3	

943	

0.5	

820	

0.5	

160	

0	

0	

0	

0	

0	

0	

1,923



.	Create, Test, Research and Development

	

28	

20,300	

16	

26,240	

16	

5,120	

380	

91,200	

155	

12,090	

0	

0	

154,950



.	Gather Information, Monitor and Inspect

	

14	

10,150	

17	

27,880	

17	

5,440	

263	

63,120	

108	

8,424	

54	

4,320	

119,334



.	Compile, Process and Review Data

	

0	

0	

0	

0	

0	

0	

0	

0	

0	

0	

18	

1,440	

1,440



.	Complete Forms

	

9	

6,525	

5.4	

8,856	

5.4	

1,728	

57	

13,680	

23	

1,794	

5.4	

432	

33,015



.	Record/ Disclose 

	

28	

20,300	

2.8	

4,592	

2.8	

896	

4.7	

1,128	

1.9	

148	

9	

720	

27,784



.	File/Store

	

3	

2,175	

1.25	

2,050	

1.25	

400	

2.75	

660	

0.9	

70	

1.58	

126	

5,482



TOTAL	

88.3	

64,018	

46	

75,030	

45	

14,368	

711	

170,525	

290	

22,622	

94	

7,542	

354,106

 ADVANCE \u2 

a ADVANCE \d2  The HON, the basis for the CAR burden estimate, requires
connector monitoring.  Sources originally complying with subpart V or VV
will not be required to perform connector monitoring if they opt to
comply with the CAR.  For this reason, a separate burden estimate was
developed for sources that are not required to perform connector
monitoring.  The per-source burden for these facilities is the average
of the per-source burden for subparts V and VV.  The average for
subparts V and VV is 294 hours, 40.9 percent less than the HON-based
estimate.  Per-source estimates for each burden item were estimated by
multiplying the HON-based estimate by 40.9 percent.

b  From most recently approved CAR ICR.

 ADVANCE \u2  ADVANCE \u2 c ADVANCE \d2  Total burden for each source
type is the product of the per-source burden and the total number of
sources estimated to opt to comply with the CAR.  The number of sources
estimated to comply with the CAR are from the most recently approved ICR
and are detailed in Table 3:

	•  process vents - 725

•  storage vessels - 1,640

•  transfer racks - 320

•  equipment leaks with connector monitoring - 240

•  equipment leaks without connector monitoring - 78

•  facilities (used for inventory estimate) - 80

 ADVANCE \u2 d  ADVANCE \d2 Total burden for each burden item is the sum
of totals for each source type.  This burden represents technical hours
only and is the basis for determining total burden in Table 5. 

TABLE 5:  ANNUAL RESPONDENT BURDEN AND COST OF REPORTING AND
RECORDKEEPING REQUIREMENTS FOR THE CAR

Burden Item	

Average Hours per Activity

(a)	

Number of Activities per year per source (b)	

Technical Hours per year per source

(c)	

Estimated Technical Hours per year

(d)	

Estimated Managerial Hours per year

(e)	

Estimated Clerical Hours per year 

(f)	

Annual Cost 

(g)



Read Rule and Instructions	

2.76	

23	

63.51	

5,081	

254	

508	

$428,102



Plan Activities	

4.90	

13	

63.71	

5,097	

255	

510	

$429,490



Training	

6.01	

4	

24.04	

1,923	

96	

192	

$161,997



Create, Test, Research and Development	

19.56	

99	

1936.88	

 154,950 	

7,748	

15,495	

$13,055,763



Gather Information, Monitor and Inspect	

2.20	

677	

1491.68	

119,334	

5,967	

11,933	

$10,054,808



Compile, Process and Review Data	

18.00	

1	

18.00	

1,440	

72	

144	

$121,331



Complete Forms	

82.54	

5	

412.69	

33,015	

1,651	

3,302	

$2,781,811



Record/ Disclose 	

13.36	

26	

347.30	

27,784	

1,389	

2,778	

$2,340,971



File/Store	

1.96	

35	

68.53	

5,482	

274	

548	

$461,880



TOTAL COST	

	

	

	

354,106	

17,706	

35,410	

$29,836,153



TOTAL BURDEN HOURS	

	

	

	

407,222	



Following is a brief explanation of each column.  A more detailed
description is provided in Attachment E.

(a) Average hours per activity are back-calculated by dividing (c) by
(b).

(b) Number of activities per year is based on the estimate of number of
activities per year for the HON, with a reduction to reflect the
consolidation of activities achieved through the CAR.

(c) Technical hours per year per source are the total technical hours
for a burden item as estimated in Table 4, divided by 80 facilities.

(d) Estimated technical hours per year are the total technical hours for
all facilities for each burden item, as estimated in Table 4.

(e) Estimated managerial hours per year are assumed to be 5 percent of
technical hours.  (e) = (d) x 0.05.

(f) Estimated clerical hours per year are assumed to be 10 percent of
technical hours.  (f) = (d) x 0.10.

(g) Annual Cost is the sum of costs for technical, managerial, and
clerical hours based on the following rates from the United States
Department of Labor, Bureau of Labor Statistics, May 2006 National
Industry-Specific Occupational Employment and Wage Estimates, NAICS
325000 Chemical Manufacturing.  The wages are for General and Operations
Managers, Environmental Engineers, and Office and Administrative Support
Occupations.  The rates have been increased by 110 percent to account
for the benefit packages available to those employed by private
industry.

Managerial	$125.87 ($59.94 + 110%)

Technical	$74.36 ($35.41 + 110%)

Clerical	$36.04 ($17.16 + 110%)

TABLE 6:  SUMMARY OF RESPONDENT BURDEN AND COST FOR REFERENCING
SUBPARTS AND THE CAR

Subpart	

(A)

Number of Respondents 

	

(B)

Total Annual Responsesa	

(C)

Respondent Burden Hoursa	

(D)

Respondent Burden Costsa	

(E)

 Agency Burden Hoursb	

(F)

Agency 

Burden 

Costsb	

(G)

Total Capital and O&M 

(Block 14 c) in 000’sc	

(H)

Capital Costs 

(Block 14a)

in 000’sc



NSPS Ka	

174	

194	

46,455	

$3,403,683	

115	

$4,743	

0	

0



NSPS Kb	

580	

1,976	

85,489	

$6,263,746	

978	

$40,475	

69	

27



NSPS VV	

436	

872	

44,123	

$3,232,749	

2,005	

$83,004	

0	

0



NSPS VVa	

76	

244	

7,146	

$527,104	

614	

$25,438	

4.2	

4.2



NSPS DDD	

90	

222	

6,755	

$494,966	

571	

$23,632	

930	

300



NSPS III	

11	

26	

296	

$21,703	

69	

$2,837	

29	

14



NSPS NNN	

1,345	

3,433	

41,880	

$3,068,545	

8,955	

$370,739	

4,206	

2,390



NSPS RRR	

155	

394	

4,789	

$350,915	

1,026	

$42,483	

578	

500



NESHAP BB	

54	

216	

12,444	

$911,831	

497	

$20,566	

0	

0



NESHAP Y	

4	

8	

65	

$4,758	

9	

$381	

0	

0



NESHAP V	

55	

123	

7,529	

$551,498	

289	

$11,957	

0	

0



NESHAP F, G, H, and I 	

245	

1,845	

1,324,711	

$97,058,100	

5,327	

$220,560	

67,513	

138



CAR 	

80	

400	

407,222	

$29,836,153	

4,087	

$169,192	

22,000	

0



TOTAL	

3,305	

9,953	

1,988,903	

$145,725,751	

24,541	

$1,016,007	

95,329	

3,373

a From Tables G-1 through G-13

b From Tables F-1 through F-12

c From Appendix J

Attachment A

Part 1:	Recordkeeping and Reporting under the Consolidated Air Rule

1.	General Records

	

The owner or operator shall keep copies of notifications, reports, and
records as specified in §65.5.

The owner or operator shall maintain a startup, shutdown, and
malfunction plan as specified in §65.6.

2.	Storage Vessel Records

Storage vessel records where emissions are controlled by a fixed roof
and internal floating roof (IFR), external floating roof (EFR), or EFR
converted into an IFR as specified in §65.47.

Storage vessel records where emissions are controlled by a control
device as specified in §65.159 for flare compliance determination and
§65.163 for closed vent systems.

Storage vessel records where emissions are routed to a fuel gas system
or process as specified in §65.163.

3.	Process Vent Records

General process vent records as specified in §§65.66, 65.63, and
65.160.

Process vent records where emissions are controlled by a control device
as specified in §65.159 for flare compliance determination records and
§§65.162 and 65.163.

Process vent records where recovery devices are used to maintain the TRE
index value above 1.0 as specified in §65.160.

4.	Transfer Rack Records

General Transfer Rack Records as specified in §§65.83, 65.87, and
65.160.

Transfer Rack Records where emissions are controlled by a control device
(except for low-throughput transfer operations) as specified in
§§65.159, 65.162, and 65.163.

•	Low-throughput transfer operation records where emissions are
controlled by a control device as specified in §§65.159 and 65.163.

5.	Equipment Leak Records

General equipment leak records as specified in §§65.103, 65.104, and
65.105.  Specific equipment leak records where equipment leak emissions
are not controlled by a control device or routed to a process or fuel
gas system as specified in §§65.106, 65.109, 65.111, and 65.120.

Equipment leak records where emissions are controlled by a control
device as specified in §§65.159 and 65.163.

6.	Notification of Initial Startup

General contents as specified in §§65.5 and 65.48.

Initial Notification of Part 65 Applicability as specified in §65.5.

7.	Initial Compliance Status Report

General contents as specified in §65.5.

Storage vessels as specified in §§65.163 and 65.164.

Process vents as specified in §§65.63, 65.67, 65.160, 65.164, and
65.165.

Low-volume transfer racks as specified in §§65.164 and 65.165.

High-volume transfer racks as specified in §§65.83, 65.164, and
65.165.		

Equipment leaks as specified in §§65.117, 65.118, 65.119, and 65.120.

8.	Periodic Reports

General contents as specified in §65.6.

Storage vessel records where emissions are controlled by an IFR, EFR, or
EFR converted into an IFR as specified in §65.48.

Storage vessels where emissions are controlled by a control device as
specified in §65.166.

Process vents as specified in §§65.67 and 65.166.

Low-volume transfer racks as specified in §65.166.

High-volume transfer racks as specified in §65.166.

Equipment leaks as specified in §65.120.

Closed vent systems as specified in §§65.143 and 65.166.

Flares as specified in §65.166.

9.	Other Notification and Reports

Request for alteration of time periods or postmark as specified in
§65.5.		

Startup, shutdown, and malfunction periodic report as specified in
§65.6 (can be included with a periodic report).

Written application for waiver of recordkeeping and reporting
requirements as specified in §65.7.

Written request for approval to use alternatives to the monitoring or
recordkeeping provisions as specified in §65.7.

Storage vessel refilling notification as specified in §65.48.

Storage vessel seal gap measurement notification as specified in
§65.48.		

Process vent Group 2A without a recovery device monitoring and
recordkeeping and reporting plan as specified in §65.63.

Process vent report of a process change if not included with the
periodic report as specified in §65.67.

Intent to conduct a performance test as specified in §65.67.

Process vent report according to the plan for Group 2A process vents
without a recovery device as specified in §65.67.

Equipment leaks written request for alternative means of emission
limitation as specified in §65.102.

Part 2:	Burden for NSPS Sources Not Electing to Comply with the CAR

Initial notifications as specified in §60.7.

Provide notification of construction or reconstruction as specified in
§60.7(a)(1).

Provide notification of anticipated startup as specified in
§60.7(a)(2).		

Provide notification of actual startup as specified in §60.7(a)(3).

Provide notification of physical or operational change as specified in
§60.7(a)(4).

Demonstration of continuous monitoring system as specified in
§60.7(a)(5).

Performance test as specified in §60.8.

Report on initial performance test results as specified in §60.8(a).

Provide notification of initial performance test as specified in
§60.8(d).

Requirements Specific to NSPS Subpart Ka

Information prior to construction on vapor recovery and return or
disposal system including emissions data, operations design
specifications, and maintenance plan as specified in
§60.113a(a)(2)(i-iv).

Submit notification 30 days prior to seal gap measurement as specified
in §60.113a(a)(1)(iv).

Report within 60 days when a seal gap measurement exceeds the limits of
§60.112a as specified in §60.113a(a)(1)(i)(E).

Record gap measurements: Secondary seals every year and Primary seals
every five years as specified in §60.113a (a)(1)(i)(D).

Record whenever the liquid is changed, stored, period of storage and
maximum true vapor pressure as specified in §60.115a(a).

Requirements Specific to NSPS Subpart Kb

Notification 30 days prior to re/filling vessel for (a)(1) and (a)(4)
IFR inspections as specified in §60.113b(a)(5).

Notice 30 days prior to seal gap measurements as specified in
§60.113b(b)(5).

Notification 30 days prior to re/filling vessel for (b)(6) EFR
inspections as specified in §60.113b(b)(6).

Submit operating plan for closed vent or exempt control device as
specified in §60.113b(c).

Report describing equipment and certifying control for IFR as specified
in §60.115b(a)(1).

Record of each inspection required at §§60.113b(a) and 60.115b(a)(2).

Report of visual defects as specified in §60.115b(a)(3).

Report of seal holes/tears as specified in §60.115b(a)(4).

Report describing equipment and certifying control for EFR as specified
in §60.115b(b)(1).

Report results of seal gap measurement required at §60.113b(b)(1)
within 60 days as specified in §60.115b(b)(2).

Record of each gap measurement required at §§60.113b(b) and
60.115b(b)(3).

Report gaps exceeding limits within 30 days of inspection required by
§§60.113b(b)(4) - 60.115b(b)(4).

Records kept on closed-vent system as specified in §60.115b(c).

Report of flare measurements as specified in §60.115b(d)(1).

Records kept on flare as specified in §60.115b(d)(2).

Report semiannually periods of pilot flame absent from flare as
specified in §60.115b(d)(3).

Records of dimensions and capacity of vessel as specified in
§60.116b(b).

Record of VOL stored, period of storage, and maximum true vapor pressure
of lower kPa vessels as specified in §60.116b(c).

Record of VOL stored, period of storage, and maximum true vapor pressure
of higher kPa vessels as specified in §60.116b(d).	

Requirements Specific to NSPS Subpart VV and VVa

Recordkeeping as specified in §§60.486 and 60.486a.

Semiannual reporting requirements as specified in §§60.487(a) through
(c) and 60.487a(a) through (c).

Notification of alternative standard selected as specified in
§§60.487(d) and 60.487a(d).		

Report Performance tests as specified in §§60.487(e) and 60.487a(e).

Requirements Specific to NSPS Subpart DDD

Initial performance test results or specified alternative reports as
specified in §60.565.

Semiannual reports of deviations from monitoring parameters, monitoring
exceedances, changes in process operations, and periods during which
control device is inoperative as specified in §60.565(k).

Records of periods when flow monitor indicates emission stream is being
diverted away from the control device as specified in §60.565(b).

Records of monitoring parameters as specified in §60.565(c), (d), (e),
(f), (g), (h).

Results of monitoring during performance tests, including the vent
system used to vent each affected stream to the control device; evidence
of compliance with incineration requirements; evidence of compliance
with boiler or process heater operation, and records from flare or pilot
light flame heat sensing monitoring and periods of operation when the
flare or pilot flame is absent as specified in §60.565(a), (b), (c),
(d), (e), (f).

Changes in production capacity, feedstock type, or catalyst type or
replacement, removal or addition of product recovery equipment or an air
oxidation reactor as specified in §60.565(g).

Evidence of compliance with elected alternative provisions, and all
periods of operation during which the performance boundaries are
exceeded as specified in §60.565(h).

Requirements Specific to NSPS Subpart III

Notification of the specific provisions of the standards which the owner
has elected to comply as specified in §60.615(a).

Record data measured during each performance test as specified in
§§60.615(b) and 60.615(h)(3).

Continuously record equipment operating parameters as specified in
§§60.615(c) and 60.615(g).

Record periods of operation during which the performance boundaries
established during the most recent performance test are exceeded as
specified in §§60.615(c) and 60.615(g).

Continuously record the indication of vent stream flow to the control
device as specified in §60.615(d).

Record all periods of operation of a boiler or process heater as
specified in §60.615(e).

Record results of flare pilot flame monitoring and all periods of
operations in which the pilot flame is absent as specified in
§60.615(f).

Record changes in production capacity, feedstock type, catalyst type, or
replacement, removal or addition of recovery equipment or an air
oxidation reactor as specified in §60.615(h)(1).

Record any recalculation of the TRE index value as specified in
§60.615(h)(2).

Written report of initial performance test results as specified in
§§60.8 and 60.615(b).

For the semiannual report exceedances of parameter boundaries
established during the most recent performance test as specified in
§60.615(j)(1).

For the semiannual report all periods when the vent stream is diverted
from the control device or has no flowrate as specified in
§60.615(j)(2).

For the semiannual report all periods when the boiler or process heater
was not operated as specified in §60.615(j)(3).

For the semiannual report all periods in which the flare pilot flame was
absent as specified in §60.615(j)(4).

For the semiannual report any recalculation of the TRE index value as
specified in §60.615(j)(5).

Requirements Specific to NSPS Subpart NNN

Notification of the specific provisions of the standards which the owner
has elected to comply as specified in §60.665(a).

Record data measured during each performance test as specified in
§§60.665(b) and 60.665(h)(3).

Continuously record equipment operating parameters as specified in
§§60.665 and 60.665(g).

Record periods of operation during which the performance boundaries
established during the most recent performance test are exceeded as
specified in §§60.665 and 60.665(g).

Continuously record the indication of vent stream flow to the control
device as specified in §60.665(d).

Record all periods of operation of a boiler or process heater as
specified in §60.665(e).

Record results of flare pilot flame monitoring and all periods of
operations in which the pilot flame is absent as specified in
§60.665(f).

Record changes in production capacity, feedstock type, catalyst type, or
replacement, removal or addition of recovery equipment or an air
oxidation reactor as specified in §60.665(h)(1).

Record any recalculation of the TRE index value as specified in
§60.665(h)(2).

Record data showing that the vent stream flowrate is less than 0.008
m3/min and any change in equipment or process operation that increases
the operating vent stream flowrate including a measurement of the new
flowrate as specified in §60.665(i).

Record any change in equipment or process operation that increases the
design production capacity of the process unit as specified in
§60.665(j).

Written report of performance test results as specified in §§60.8 and
60.665(b).

For demonstrating compliance with the low capacity exemption levels, a
report detailing the design production capacity of the process unit as
specified in §60.665(n).

For demonstrating compliance with the low flow exemption level, a report
of the flowrate measurement as specified in §60.665(o).

For the semiannual report, exceedances of parameter boundaries
established during the most recent performance test as specified in
§60.665(l)(1).

For the semiannual report, all periods when the vent stream is diverted
from the control device or has no flowrate as specified in
§60.665(l)(2).

For the semiannual report, all periods when the boiler or process heater
was not operated as specified in §60.665(l)(3).

For the semiannual report, all periods in which the flare pilot flame
was absent as specified in §60.615(j)(4).

For the semiannual report, any change in equipment or process operation
that increases the operating vent stream flowrate above the low flow
exemption level as specified in §60.665(l)(5).

For the semiannual report, any change in equipment or process operation
that increases the design production capacity above the low capacity
exemption level as specified in §60.665(l)(6).

For the semiannual report, any recalculation of the TRE index value as
specified in §60.665(l)(7).

Requirements Specific to NSPS Subpart RRR

Notification of the specific provisions of the standards which the owner
has elected to comply as specified in §60.705(a).

Exceedances of parameter boundaries established during the most recent
performance test as specified in §60.705(l)(1).

All periods when the vent stream is diverted from the control device or
has no flowrate as specified in §60.705(l)(2).

All periods in which the flare pilot flame was absent as specified in
§60.705(l)(3).

For the semiannual report, any changes in equipment or process operation
that increases the operating vent stream flowrate above the low flow
exemption level as specified in §60.705(l)(4).

For the semiannual report, any change in equipment or process operation,
that increases the design production capacity above the low capacity
exemption level as specified in §60.705(l)(5).

For the semiannual report, any recalculation of the TRE index value as
specified in §60.705(l)(6).

For the semiannual report, all periods recorded in which the seal
mechanism is broken or the bypass line valve position has changed.  A
record of the serial number of the car-seal or a record to show that the
key to unlock the bypass line valve was checked out must be maintained
to demonstrate the period, the duration, and frequency in which the
bypass line was operated as specified in §60.705(l)(7).

For the semiannual report, any change in equipment or process operation
that increases the vent stream concentration above the low concentration
exemption level, including a measurement of the new vent stream
concentration as specified in §60.705(l)(8).

For the initial report, written report of performance test results as
specified in §§60.8 and 60.705(b).

Record data measured during each performance test as specified in
§§60.705(b) and 60.705(g)(3).

Continuously record equipment operating parameters as specified in
§60.705(c).

Records of diversion of vent stream from the control device as specified
in §60.705(d)(1).

Record results of flare pilot flame monitoring and all periods of
operations in which the pilot flame is absent as specified in
§60.705(e).		

Record periods of operation during which the performance boundaries
established during the most recent performance test are exceeded as
specified in §60.705(f).

Record changes in production capacity, feedstock type, catalyst type, or
replacement, removal or addition of recovery equipment as specified in
§60.705(g)(1).

Record any recalculation of the TRE index value as specified in
§60.705(g)(2).

Records to indicate that the vent stream flowrate is less than 0.011
scm/min and of any change in equipment or process operation that
increases the operating vent stream flowrate, including measurement of
the new vent stream flowrate as specified in §60.705(h).

Each owner or operator of an affected facility that seeks to comply with
the requirements of this subpart by complying with the design production
capacity provision, shall keep up-to-date, readily accessible records of
any change in equipment or process operation that in creases the design
production capacity of the process unit in which the affected facility
is located as specified in §60.705(i).

Each owner or operator of an affected facility that seeks to complying
with the low concentration exemption, shall keep up-to-date, readily
accessible records of any change in equipment or process operation that
increases the concentration of the vent stream of the affected facility
as specified in §60.705(j).

Part 3:	Burden for 40 CFR Part 61 NESHAP Sources Not Electing to Comply
with the CAR

Construction or modification application as specified in §61.07.		

Provide notification of anticipated startup as specified in
§61.09(a)(1). 

Provide notification of actual startup as specified in §61.09(a)(2).		

Source status report as specified in §61.10(a).

Initial performance test as specified in §61.13.

Provide notification of initial performance test as specified in
§61.13.

Report on initial performance test results as specified in §61.13(f).		

Provide notification of physical or operational change as specified in
§61.15 .

Requirements Specific to NESHAP Subpart V

Application for alternative means of emissions limitation as specified
in §61.244.

Recordkeeping as specified in §61.246.

Reporting as specified in §61.247.

Requirements Specific to NESHAP Subpart Y

Initial source report as specified in §61.274.

Report of annual and periodic inspections for IFR as specified in
§61.275(a).

Supplemental annual periodic report for IFR as specified in §61.275(a).

Report of 5 or 10 year internal inspections for IFR as specified in
§61.275(b).

Report of annual seal gap measurements for EFR as specified in
§61.275(d).

Report of 5 year seal gap measurements for EFR as specified in
§61.275(d).

Report of excess emissions for closed vent systems with control devices
as specified in §61.275(e).

Record of storage vessel design capacity as specified in §61.276(b).

Record of information on closed vent systems with control devices as
specified in §61.276(c).

Requirements Specific to NESHAP Subpart BB

Obtain vapor tightness documentation at §61.305(h) every 12 months as
specified in §61.302(d).

Maintain vapor-tightness file on each affected facility as specified in
§61.302(d) and (e).

Record of measurements during each performance test as specified in
§61.305(a).

Engineering report as specified in §61.305(a)(5).

Record of monitoring equipment parameters and excess emissions as
specified in §61.305(b).

Record vent valves status and maintain for at least two years as
specified in §61.305(c).

Records of periods of operation of steam generator or process heater
kept up-to-date as specified in §61.305(d).

Records of flare operation and monitoring kept up-to-date as specified
in §61.305(e).

Quarterly report by sources subject to as specified in §61.302, and
controls as specified in §61.305(f).

Documentation of vapor-tightness required under §61.302(d) and (e) on
permanent file as specified in §61.305 (g).

Documentation of vapor-tightness renewed at least once per year as
specified in §61.305(h).

Record and report information when exempt under §§61.300(b) and
61.305(i).

Record of closed-vent system annual leak inspection required at
§§61.242-ll(f)(2) through 61.302(k), and 61.246(d).

Part 4:	Burden for 40 CFR Part 63 NESHAP Sources Not Electing to Comply
with the CAR (MACT Subparts F, G, H and I: The HON)

1.	Notifications

Notification of construction or reconstruction as specified in §§63.5,
63.9, 63.100, 63.151, 63.182, and 63.192.

Notification of anticipated date of initial startup as specified in
§§63.5, 63.9, 63.151, 63.182, and 63.192.

Notification of actual date of initial startup as specified in §§63.9,
63.151, 63.182, and 63.192.

Notification of process changes as specified in §§63.100, 63.118,
63.146, 63.151, 63.152, 63.182, and 63.192.

Notification of performance test as specified in §63.103.

Notification for storage tanks as specified in §63.192.

2.	Reporting - Initial and Notification of Compliance Status

Initial report requirements as specified in §§63.117, 63.122, 63.129,
63.146, 63.151, 63.182, and 63.192.

Reporting of operating parameter levels as specified in §§63.117,
63.120, 63.122, 63.129, 63.130, 63.146, 63.151, 63.182, and 63.192.

Statement of compliance/noncompliance as specified in §§63.117,
63.120, 63.122, 63.127, 63.128, 63.129, 63.151, 63.152, 63.182, and
63.192.

3.	Reporting - Periodic and Event Triggered

Startup, shutdown and malfunction as specified in §§63.6, 63.10,
63.103, and 63.105.

Exceedance of parameter boundaries established during the most recent
performance test as specified in §§63.118, 63.122, 63.130, 63.146,
63.148, 63.151, 63.152, 63.182, and 63.192.

Any change in equipment or process operation that increases emission
levels above requirements in the standard as specified in §§63.103,
63.104, 63.122, 63.130, 63.146, 63.148, 63.151, 63.152, 63.182, and
63.192.

Written report of performance tests as specified in §§63.117, 63.120,
63.122, 63.129, 63.146, 63.151, 63.152, 63.182, and 63.192.

Delay of repair as specified in §§63.104, 63.122, 63.182, and 63.192.

4.	Recordkeeping

General Recordkeeping as specified in §63.103.

Record of data measured during each performance test as specified in
§§63.117, 63.118, 63.123, 63.129, 63.130, 63.147, 63.148, 63.151,
63.152, 63.181, and 63.192.

Record of periods of operation during which the performance boundaries
established in the Notification of Compliance Status are exceeded as
specified in §§63.118, 63.120, 63.123, 63.130, 63.147, 63.148, 63.151,
and 63.152.

Records of Monthly visual inspections as specified in §§63.118,
63.130, 63.147, 63.148, 63.181, and 63.192.

Records of Annual visual inspections as specified in §§63.123, 63.147,
63.148, 63.181 and 63.192.

TRE records for process vents as specified in §63.117.

Monitoring records as specified in §§63.118 and §63.123.		

Records of process changes for process vents as specified in §63.118.

Records of delay of repair as specified in §§63.120 and §63.123.

Record of storage vessel size as specified in §63.123.

•	Record of vent system configuration for transfer racks as specified
in §63.129.

•	Record of design criteria for equipment leaks as specified in
§63.118.

•	Record of startup, shutdown and malfunction as specified in
§§63.6, 63.103, 63.105, and 63.152.

•	Records of continuous monitoring systems as specified in §63.103.

Attachment B

Purposely left blank.

Attachment C

Assumptions and Item Descriptions for Table 3

Assumptions are the same as Attachment E, and:

(A) That there are 318 total sources (240 from the HON, 59 from Subpart
VV, 0 from Subpart VVa, and 19 from Subpart V) that must submit
semiannual reports from equipment leak detection and repair programs as
well as semiannual periodic reports.  This equates to 636 EPA activities
(318 * 2) during each of the three years following promulgation.

(B) That all sources must submit an Initial Notification of Part 65
Applicability or submit the corresponding information in a modification
to their Title V permits.  This equates to 80 EPA activities, or 27 per
year (80/3) during each of the three years following promulgation.

Item descriptions:

(a) Average Hours per Activity are estimates of the specific activities
and are the basis for estimating the overall burden.

(b) Number of Activities per Year represents the number of reports
expected to be reviewed and other related activities during the course
of the year, based upon assumptions (A) and (B).

(c) Estimated Technical Hours per Year is the product of (a) and (b).

(d) Estimated Managerial Hours per Year is 5 percent of (c).

(e) Estimated Clerical Hours per Year is 10 percent of (c).

(f) Estimated Annual Cost in $ Thousands per Year is the total cost of
technical, managerial, and clerical hours and overhead using this
formula:

(Ht * $42.45/hour) + (Hm * $57.20/hour) + (Hc * $22.96/hour) = (h)

1,000

Where:

Ht is (c), or technical hours,

Hm is (d), or managerial hours, and

Hc is (e), or clerical hours.

Source:

Annual cost is the sum of costs for technical, managerial, and clerical
hours based on rates from the Office of Personnel Management (OPM)
“2006 General Schedule” which excludes locality rates of pay.

Technical - $42.45 (GS-12, Step 1, $26.53 x 1.6)

Managerial - $57.20 (GS-13, Step 5, $35.75 x 1.6)

Clerical - $22.96 (GS-6, Step 3, $14.35 x 1.6)

1) Initial Notification of Part 65 Applicability/Title V Modification
represents the EPA review of either the Initial Notification of Part 65
Applicability report or the source’s Title V modification through
which the source notifies EPA that it intends to comply with the CAR. 
As noted in the supporting statement text, the EPA does not expect any
new sources to elect to comply with the CAR during the 3-year period
following promulgation.

2) Review Equipment Leak Monitoring represents the review and screening
of periodic reports received as a result of the equipment leaks
standard.

3) Review Periodic Reports represents the EPA review of periodic reports
from new and existing sources.

TOTAL BURDEN AND COST is the total for each of the columns (c), (d),
(e), and (f).

Attachment D

Purposely left blank.

Attachment E

Assumptions and Item Descriptions for Table 6 

Assumptions are:

(A) That there are 320 existing facilities, of which 25 percent (80)
chose to comply with the CAR.

(B) That the average representative source will consist of a variety of
sources.  The total number of sources expected to comply with the CAR
includes (from Table 4):

•	1,640 storage vessels;

•	320 transfer racks;

•	240 collections of subject equipment, including connectors;

•	78 collections of subject equipment, not including connectors; 

(	80 facility wide inventories of emission points; and

•	725 process vents.

(C) That there are 5 percent (0.05) managerial and 10 percent (0.10)
clerical hours required for every technical hour.

(D) That some activities necessary to generate reports involve creating
records in the process, and that these activities are assumed to be
reports activities alone, to avoid double counting these as records
activities as well.  Therefore, only items 8 and 9 are considered
records burdens directly.

Item descriptions:

(a) Average Hours per Activity is back-calculated by dividing (b)
into (c).  Since the activities within each burden category can vary
significantly, it is too inaccurate to assume an average to use to
calculate (c).  Estimated activity technical hours are calculated in
Table 5 and entered into column (c); (a) is then back-calculated with an
estimated (b).

(b) Estimated Number of Activities per Year per Source represents the
assumed typical number of separate activities a source may encounter
during one year.  This number may vary from facility to facility
depending on consolidation of activities, co-located readings, etc. 
Since so much variability exists, it is important to note that this an
estimate.  This number was only used to back-calculate (a).  The
numbers are based on the number of activities per year estimated for
complying with the HON.  The numbers have been reduced to reflect the
consolidation of activities achieved through the CAR.

(c) Technical Hours per Year per Source is the total technical hours for
a burden item, as estimated in Table 7 divided by 80 facilities. 
Because of the variability in the number and combination of sources at a
facility, this value could vary widely.

(d) Estimated Technical Hours per Year is the sum of total technical
hours for all sources for each burden item, as estimated in Table 7.

(e) Estimated Managerial Hours per Year is 5 percent of (d).

(f) Estimated Clerical Hours per Year is 10 percent of (d).

(g) Estimated Annual Cost in Thousands of Dollars per Year is the total
cost of technical, managerial, and clerical hours and overhead using
this formula:

(Ht * $74.36/hour) + (Hm * $125.87/hour) + (Hc * $36.04/hour)=(g)

Where:

Ht is (d), or technical hours,

Hm is (e), or managerial hours, and

Hc is (f), or clerical hours.

Source:

United States Department of Labor, Bureau of Labor Statistics, May 2006
National Industry-Specific Occupational Employment and Wage Estimates,
NAICS 325000 Chemical Manufacturing.  The wages are for Environmental
Engineers, General and Operations Managers, and Office and
Administrative Support Occupations.  The rates have been increased by
110 percent to account for the benefit packages available to those
employed by private industry.

1) Read Rule and Instructions consists of the activities, less training,
which involve comprehending the provisions in the standard and
understanding how they apply to the respective points at a facility.

2) Plan Activities represents such burdens as design, redesign, and
scheduling, as well as selecting methods of compliance.

3) Training represents the portion of activities from 1) Read Rule and
Instructions for which an average facility would elect to provide class
room instruction.  The standard does not require specific training
itself.

4) Create, Test, Research and Development are the activities involving
testing, retesting, establishing operating ranges for parameters, and
analyzing point by point applicability.  Monitor-related refit,
calibration, and maintenance activities are also included under this
heading.

5) Gather Information, Monitor, and Inspect are the activities involving
physical inspections of equipment, collection of monitored data, and
other related activities.

6) Process/Compile and Review are the activities that involve analysis
of the information collected for accuracy and compliance as well as
appropriate records and reports required as a result.

7) Complete Reports represents the activities normally associated with
filling out forms.  Since the standard requires no standard forms, these
activities relate to the preparing of formal reports and cover letters.

8) Record/Disclose are solely recordkeeping activities which occur once
the appropriate report information has been extracted; see assumption
(D).  These activities involve software translation, duplication, or
archival processes normally associated with data management and storage
common to this industry.

9) Store/File are activities which are solely recordkeeping which occur
once the appropriate report information has been extracted; see
assumption (D).  These activities involve the management life cycle of
records, from the time they are filed and boxed up to the time they are
disposed.

TOTAL BURDEN AND COST is the total for each of the columns (d), (e),
(f), and (g).

ATTACHMENT F:  EPA BURDEN AND COST FOR REFERENCING SUBPARTS

TABLE F-1:  AVERAGE ANNUAL EPA RESOURCE REQUIREMENT FOR SUBPART Kaa

Activity	

(A)

EPA/hr Occurrence	

(B)

Occurrences/

plant/yr	

(C =AxB)

EPA hr/

plant/yr	

(D) ADVANCE \d2 

Plants/

yr	

(E=CxD)

Technical  hr/yr	

(F=Ex0.05)

Managerial hr/yr	

(G=Ex0.10) Clerical hr/yr	

(H)

Total Cost/ yre



Report Review:  New Plant	

	

	

	

	

	

	

	





Vapor recoveryb 	

N/A	

	

	

	

	

	

	





Report Review:  Existing Plant	

	

	

	

	

	

	

	





Notification of Reconstruction	

2	

1	

2	

0	

0	

0	

0	

$0



Notification of Modification	

2	

1	

2	

0	

0	

0	

0	

$0



Notification of seal gap measurement c	

0.5	

1	

0.5	

188	

94	

5	

9	

$4,481



Report of gap excessesc,d	

1	

1	

1	

6 ADVANCE \d2 	

6	

0	

1	

$262



TOTAL ANNUAL HOURS	

	

	

	

	

100	

5	

10	





TOTAL ANNUAL BURDEN	

	

	

	

	

115	

$4,743

a Assume no new sources subject to this regulation.  All similar new
sources will be subject to Subpart Kb.

b Required only at start of construction.  Any new storage vessel being
constructed would be subject to the NSPS Subpart Kb.

c Assume that 90 percent of the storage vessels will use a floating roof
and be subject to seal gap measurement.  The remaining 10 percent will
use a closed vent system.

d Assume 25 percent of respondents using a floating roof will have
excessive seal gaps requiring that a single report be filed once per
year.

e Annual cost is the sum of costs for technical, managerial, and
clerical hours based on rates from the Office of Personnel Management
(OPM) “2006 General Schedule” which excludes locality rates of pay.

Technical - $42.45 (GS-12, Step 1, $26.53 x 1.6)

Managerial - $57.20 (GS-13, Step 5, $35.75 x 1.6)

Clerical - $22.96 (GS-6, Step 3, $14.35 x 1.6)

TABLE F-2:  AVERAGE ANNUAL EPA RESOURCE REQUIREMENT FOR SUBPART Kb

Reporting and Recordkeeping Requirements Assumptionsa	

(A)

Technical hr/yr	

(B=A*.05)

Managerial hr/yr	

(C=A*.10)

Clerical hr/yr	

Cost/yr

$ ADVANCE \u2 a



Report Review	

	

	

	





Notification of construction; 37b new notifications @ 2 hr/ea	

74	

4	

7	

$3,531



Notice of anticipated startup; 37 new notifications @ 1 hr/ea	

37	

2	

4	

$1,777



Notice of actual startup; 37 new notifications @ 1 hr/ea	

37	

2	

4	

$1,777



Notification of initial inspection; @1 hr/ea	

37	

2	

4	

$1,777



IFR Failure Reportc; 55 sources @ 1 hr/ea	

55	

3	

6	

$2,644



Notification of Delay for Repair/Emptying IFRd; 6 sources @ 1.2 hr/ea	

7	

0	

1	

$320



Notification to Re-Filld; 602 sources @ 1 hr/ea	

602	

30	

60	

$28,649



TOTAL ANNUAL HOURS	

849	

43	

86	





TOTAL ANNUAL BURDEN	

978	

$40,475

a Annual cost is the sum of costs for technical, managerial, and
clerical hours based on rates from the Office of Personnel Management
(OPM) “2006 General Schedule” which excludes locality rates of pay.

Technical - $42.45 (GS-12, Step 1, $26.53 x 1.6)

Managerial - $57.20 (GS-13, Step 5, $35.75 x 1.6)

Clerical - $22.96 (GS-6, Step 3, $14.35 x 1.6)

b Assume 111 new storage tanks will be constructed during each of the
next three years, or 37 tanks per year (28 IFRs, 7 EFRs, 2 CVS).

c One percent failure rate for the 5468 IFRs choosing annual visual
inspections equals approximately 55.

d From Table G-2

TABLE F-3:  AVERAGE ANNUAL EPA RESOURCE REQUIREMENT FOR SUBPART VV

Activity	

(A)

EPA/hr Occurrence	

(B)

Occurrences/

plant/yr	

(C)

Plants/yr	

(D)a

Technical

hr/yr	

(E=F*.05)

Managerial hr/yr	

(G=F*.10)

Clerical 

hr/yr	

Cost/yrd



Report Review: New Plant	

	

	

	

	

	

	





Notification of Construction	

8	

1	

0b	

0	

0	

0	

$0



Notification of Reconstruction/ Modification	

2	

1	

0	

0	

0	

0	

$0



Notification of Actual Startup	

0.5	

1	

0	

0	

0	

0	

$0



Notification of Initial/Repeat Test	

0.5	

1	

0c	

0	

0	

0	

$0



Review Test Results	

2	

1	

0c	

0	

0	

0	

$0



Report Review: Existing Plant

Semiannual Emission Reports	

2	

2	

436c	

1,744	

87	

174	

$83,004



TOTAL ANNUAL HOURS	

	

	

	

1,744	

87	

174	





TOTAL ANNUAL BURDEN	

	

	

	

2,005	

$83,004

a D=AxBxC

b All new sources will be subject to subpart VVa.

c There are an average of 436 existing sources per year for the next
three years, based on the assumption of 525 sources in the first and
second year, and 258 in the 3rd year (when sources will become subject
to the MON).  The 525 sources is based on an estimated 1272 process
units making SOCMI chemicals, of which 879 are potentially subject to
the HON, and 393 are potentially subject to the MON.  All of them are
assumed to have been constructed, reconstructed, or modified since the
effective date of subpart VV and thus subject to subpart VV.  Of the 879
processes making HON chemicals, 15 percent (132) are estimated to be at
area sources and thus subject only to subpart VV, not the HON.  All 393
process units making MON chemicals are assumed to be subject only to
subpart VV in the first two years.  For the third year, after the
effective date of the MON, it is assumed that only 126 of the 393 will
still be subject to subpart VV (an estimated 59 at area sources and 67
that emit only VOC, no HAP).  Sources subject to both subpart VV and
either the MON or HON are assumed to be complying with the HON or MON
and are not included in this analysis.  This analysis may overestimate
the number of sources because it assumes each source has only one
affected process unit.

 ADVANCE \u2 d Annual cost is the sum of costs for technical,
managerial, and clerical hours based on rates from the Office of
Personnel Management (OPM) “2006 General Schedule” which excludes
locality rates of pay.

Technical - $42.45 (GS-12, Step 1, $26.53 x 1.6)

Managerial - $57.20 (GS-13, Step 5, $35.75 x 1.6)

Clerical - $22.96 (GS-6, Step 3, $14.35 x 1.6)

	TABLE F-4:  ANNUAL AVERAGE EPA RESOURCE REQUIREMENT FOR SUBPART DDD	

Activity	

(A)

EPA hr/

Occurrence	

(B)

Occurrences plant/yr	

(C)

Plants/yr	

(D)a

Technical hr/yr	

(E=D*.05)

Managerial hr/hr	

(F=E*.10)

Clerical hr/yr	

(G)b Cost/yr

($)



Report Review	

	

	

	

	

	

	





Notification of Construction/ Reconstruction/Modification	

2	

1	

10	

20	

1	

2	

$952



Notification of Actual Startup	

2	

1	

10	

20	

1	

2	

$952



Initial Performance Test	

8	

1	

10	

80	

4	

8	

$3,808



Repeat Performance Testd	

8	

0.2	

10	

16	

1	

2	

$782



Semiannual Reports	

2	

2	

90c	

360	

18	

36	

$17,138



TOTAL ANNUAL HOURS	

	

	

	

496	

25	

50	





TOTAL ANNUAL BURDEN	

	

	

	

571	

$23,632

 ADVANCE \u2 a D=AxBxC

b Annual cost is the sum of costs for technical, managerial, and
clerical hours based on rates from the Office of Personnel Management
(OPM) “2006 General Schedule” which excludes locality rates of pay.

Technical - $42.45 (GS-12, Step 1, $26.53 x 1.6)

Managerial - $57.20 (GS-13, Step 5, $35.75 x 1.6)

Clerical - $22.96 (GS-6, Step 3, $14.35 x 1.6)

c Average number of affected sources over next three years.

d Assume 20 percent of performance tests repeated due to failure.

TABLE F-5:  AVERAGE ANNUAL EPA RESOURCE REQUIREMENT FOR SUBPART III

Activity	

(A)

EPA hr/

Occurrence	

(B)

Occurrences/plant/yr	

(C)

Plants/yr	

(D)a

Technical hr/yr	

(E=D*.05)

Managerial hr/hr	

(F=E*.10)

Clerical hr/yr	

(G)b 

Cost/yr

($)



Report Review	

	

	

	

	

	

	





Notification of Construction/ Reconstruction/ Modification	

2	

1	

1	

2	

0.1	

0.20	

$95



Notification of Anticipated Startup	

2	

1	

1	

2	

0.1	

0.20	

$95



Notification of Actual Startup	

2	

1	

1	

2	

0.1	

0.20	

$95



Initial Test	

8	

1	

1	

8	

0.4	

0.80	

$381



Repeat Performance Testc	

8	

0.2	

1	

1.6	

0.08	

0.16	

$76



Semiannual Reports	

2	

2	

11d	

44	

2.2	

4.40	

$2,095



TOTAL ANNUAL HOURS	

	

	

	

59.6	

2.98	

5.96	





TOTAL ANNUAL BURDEN	

	

	

	

69	

$2,837

a D=AxBxC

b Annual cost is the sum of costs for technical, managerial, and
clerical hours based on rates from the Office of Personnel Management
(OPM) “2006 General Schedule” which excludes locality rates of pay.

Technical - $42.45 (GS-12, Step 1, $26.53 x 1.6)

Managerial - $57.20 (GS-13, Step 5, $35.75 x 1.6)

Clerical - $22.96 (GS-6, Step 3, $14.35 x 1.6)

c Assume 20 percent of performance tests are repeated due to failure.

d Average number of affected sources over next three years.  Does not
include sources subject to both Subpart III and the HON, which are
assumed to be complying with the HON.

	TABLE F-6:  AVERAGE ANNUAL EPA RESOURCE REQUIREMENT FOR SUBPART NNN	

 ADVANCE \u2 

Activity	

(A)

EPA hr/

Occurrence	

(B)

Occurrences/ plant/yr	

(C)

Plants/ yr	

(D)a

Technical hr/yr	

(E=D*.05)

Managerial hr/yr	

(F=E*.10)

Clerical hr/yr	

(G)b 

Cost/yr

($)



Report Review	

	

	

	

	

	

	





Notification of Construction/ Reconstruction/Modification	

2	

1	

177	

354	

18	

35	

$16,861



Notification of Actual Startup	

2	

1	

177	

354	

18	

35	

$16,861



Initial Test	

8	

1	

177	

1,416	

71	

142	

$67,431



Repeat Performance Testc	

8	

0.2	

177	

283	

14	

28	

$13,466



Semiannual Reports	

2	

2	

1,345d	

5,380	

269	

538	

$256,120



TOTAL ANNUAL HOURS	

	

	

	

7,787	

390	

778	





TOTAL ANNUAL BURDEN	

	

	

	

8,955	

$370,739

a D=AxBxC

b Annual cost is the sum of costs for technical, managerial, and
clerical hours based on rates from the Office of Personnel Management
(OPM) “2006 General Schedule” which excludes locality rates of pay.

Technical - $42.45 (GS-12, Step 1, $26.53 x 1.6)

Managerial - $57.20 (GS-13, Step 5, $35.75 x 1.6)

Clerical - $22.96 (GS-6, Step 3, $14.35 x 1.6)

c Assume 20 percent of performance tests are repeated due to failure.

d Average number of affected sources over next three years.  Does not
include sources subject to both Subpart NNN and the HON, which are
assumed to be complying with the HON.

TABLE F-7:  AVERAGE ANNUAL EPA RESOURCE REQUIREMENT FOR SUBPART RRR

Activity	

(A)

EPA hr/

Occurrence	

(B)

Occurrences/ plant/yr	

(C)

Plants/yr	

(D)a

Technical

 hr/yr	

(E=D*.05)

Managerial hr/yr	

(F=E*.10)

Clerical

 hr/yr	

(G)

Cost/yr

$b



Report Review	

	

	

	

	

	

	





Notification of Construction/ Reconstruction/Modification	

2	

1	

20	

40	

2	

4	

$1,904



Notification of Actual Startup	

2	

1	

20	

40	

2	

4	

$1,904



Initial Test	

8	

1	

20	

160	

8	

16	

$7,617



Repeat Performance Testc	

8	

0.2	

20	

32	

2	

3	

$1,542



Semiannual Reports	

2	

2	

155d	

620	

31	

62	

$29,516



TOTAL ANNUAL HOURS	

	

	

	

892	

45	

89	





TOTAL ANNUAL BURDEN	

	

	

	

1,026	

$42,483

a D=AxBxC

b Annual cost is the sum of costs for technical, managerial, and
clerical hours based on rates from the Office of Personnel Management
(OPM) “2006 General Schedule” which excludes locality rates of pay.

Technical - $42.45 (GS-12, Step 1, $26.53 x 1.6)

Managerial - $57.20 (GS-13, Step 5, $35.75 x 1.6)

Clerical - $22.96 (GS-6, Step 3, $14.35 x 1.6)

c Assume 20 percent of performance tests are repeated due to failure.

d Average number of affected sources over next three years.  Does not
include sources subject to both Subpart NNN and the HON, which are
assumed to be complying with the HON.

TABLE F-8:  AVERAGE ANNUAL EPA RESOURCE REQUIREMENT FOR SUBPART BB

Activity	

(A)

EPA/hr Occurrence	

(B)

Occurrences/

plant/yr	

(C)b

Plants/yr	

(D)

Technical 

hrs/yra	

(E=D*.05)c

Managerial

hr/yr	

(F=D*.1)

Clerical 

hr/yr	

(G)

Cost/yr

$d



Report Review: New Plantc	

	

	

	

	

	

	





Notification of construction	

0.5	

0	

0	

0	

0	

0	

$0



Notification of anticipated startup	

0.5	

0	

0	

0	

0	

0	

$0



Notification of actual startup 	

0.5	

0	

0	

0	

0	

0	

$0



Initial report	

8	

0	

0	

0	

0	

0	

$0



Notification of emission test	

0.5	

0	

0	

0	

0	

0	

$0



Result of emission test	

4	

0	

0	

0	

0	

0	

$0



Notification of performance test	

0.5	

0	

0	

0	

0	

0	

$0



Result of performance test	

8	

0	

0	

0	

0	

0	

$0



Review test results	

8	

0	

0	

0	

0	

0	

$0



Report Review: Existing Plant	

	

	

	

	

	

	





Quarterly reports	

2 ADVANCE \u2  ADVANCE \d2 	

4	

54	

432	

22	

43	

$20,566



TOTAL ANNUAL HOURS	

	

	

	

432	

22	

43	





TOTAL ANNUAL BURDEN	

	

	

	

497	

$20,566

a D=AxBxC

b Assume an estimated total of 81 facilities.  Assume 2/3 (54)
facilities are marine vessel loading facilities and must continue to
comply with this Subpart; assume 2 of these 54 marine vessel loading
facilities also load tank trucks and railcars that are not subject to
the HON.

c Assume no new sources.

d Annual cost is the sum of costs for technical, managerial, and
clerical hours based on rates from the Office of Personnel Management
(OPM) “2006 General Schedule” which excludes locality rates of pay.

Technical - $42.45 (GS-12, Step 1, $26.53 x 1.6)

Managerial - $57.20 (GS-13, Step 5, $35.75 x 1.6)

Clerical - $22.96 (GS-6, Step 3, $14.35 x 1.6)

TABLE F-9:  AVERAGE ANNUAL EPA RESOURCE REQUIREMENT FOR SUBPART Y

Activity	

(A)

EPA/hr Occurrence	

(B)

Occurrences/

plant/yr	

(C)a

Plants/yr	

(D)

Technical 

hr/yrb	

(E=D*.05) ADVANCE \d2 

Managerial 

hr/yr	

(F=D*.10)

Clerical

hr/yr ADVANCE \d2 	

(G)

Cost/yr

$c



Report Review: New Plant	

	

	

	

	

	

	





Notification of construction	

Included in 

NSPS Kb	

	

	

	

	

	





Notification of anticipated startup	

Included in NSPS Kb	

	

	

	

	

	





Notification of actual startup 	

Included in NSPS Kb	

	

	

	

	

	





Notification of performance test	

N/A	

N/A	

N/A	

N/A	

N/A	

N/A	





Report of performance test	

N/A	

N/A	

N/A	

N/A	

N/A	

N/A	





Notification of control installation and refill at 1st degassingd	

1	

1	

0	

0	

0	

0	

$0



Report Review: Existing Plant	

	

	

	

	

	

	





Annual IFR internal inspections and EFR seal gap measurements	

2	

1 ADVANCE \u2  ADVANCE \d2 	

4	

8	

0	

1	

$381



Supplemental delay reporte	

1	

1	

0	

0	

0	

0	

$0



Quarterly emission reportsf	

N/A	

N/A	

N/A	

N/A	

N/A	

N/A	

N/A



TOTAL ANNUAL HOURS	

	

	

	

8	

0.4	

0.8	





TOTAL ANNUAL BURDEN	

	

	

	

9	

$381

a Estimate that there are 4 existing sources not covered by the HON. 
All new source burden is included in the NSPS Subpart Kb regulation for
storage vessels at 40 CFR Part 60.

b D=AxBxC

c Annual cost is the sum of costs for technical, managerial, and
clerical hours based on rates from the Office of Personnel Management
(OPM) “2006 General Schedule” which excludes locality rates of pay.

Technical - $42.45 (GS-12, Step 1, $26.53 x 1.6)

Managerial - $57.20 (GS-13, Step 5, $35.75 x 1.6)

Clerical - $22.96 (GS-6, Step 3, $14.35 x 1.6)

d It is believed that all vessels have been degassed and all controls
have been installed as they were to have been installed within 10 years
of promulgation (1999).

e Estimate that two percent of existing sources will request delay of
repair in the annual report.

f Assume that no source will select the fixed roof vented to a control
device option and, thus, have no quarterly report of excess emissions.

TABLE F-10:  AVERAGE ANNUAL EPA RESOURCE REQUIREMENT FOR SUBPART V

Activity	

(A)

EPA hr/

Occurrence	

(B)

Occurrences/plant/yr	

(C)

Plants/yrb	

(D)a

Technical hr/yr	

(E=D*.05)

Managerial hr/yr	

(F=E*.10)

Clerical hr/yr	

(G)

Cost/yr

$d



Report Review	

	

	

	

	

	

	





Notification of Construction/ Reconstruction/Modification	

2	

1	

2	

4	

0.20	

0.40	

$190



Notification of Anticipated Startup	

2	

1	

2	

4	

0.20	

0.40	

$190



Notification of Actual Startup	

2	

1	

2	

4	

0.20	

0.40	

$190



Initial Test	

8	

1	

2	

16	

0.80	

1.60	

$762



Repeat Performance Testc	

8	

0.2	

2	

3	

0.16	

0.32	

$152



Semiannual Reports	

2	

2	

55	

220	

11.00	

22.00	

$10,473



TOTAL ANNUAL HOURS	

	

	

	

251	

13	

25	





TOTAL ANNUAL BURDEN	

	

	

	

289	

$11,957

a D=AxBxC

b Assume 2 new sources per year at one new facility and 55 existing
process units subject to NESHAP V, but not the HON.

c Assume 20 percent of initial performance test must be repeated due to
failure.

d Annual cost is the sum of costs for technical, managerial, and
clerical hours based on rates from the Office of Personnel Management
(OPM) “2006 General Schedule” which excludes locality rates of pay.

Technical - $42.45 (GS-12, Step 1, $26.53 x 1.6)

Managerial - $57.20 (GS-13, Step 5, $35.75 x 1.6)

Clerical - $22.96 (GS-6, Step 3, $14.35 x 1.6)

TABLE F-11:  AVERAGE ANNUAL EPA RESOURCE REQUIREMENT FOR SUBPARTS F, G,
H, and I

Burden Item	

Average Hours

per Activity

(a)	

Number of Activities per Year

(b)	

Estimated Technical Hours per year

(c)	

Estimated Managerial Hours per year 

(d)	

Estimated Clerical Hours per year 

(e)	

Annual Cost $

(f)



Report Review	

	

	

	

	

	





Initial	

2	

5	

10	

1	

1	

$505



Implementation Plan or Permit	

20	

5	

100	

5	

10	

$4,761



Compliance status	

40	

5	

200	

10	

20	

$9,521



Equipment leak monitoring	

7	

240	

1,680	

84	

168	

$79,978



Notification of Construction/ Reconstruction	

2	

5	

10	

1	

1	

$505



Notification of anticipated startup	

2	

5	

10	

1	

1	

$505



Notification of actual startup	

2	

5	

10	

1	

1	

$505



Notification of Performance Test	

2	

5	

10	

1	

1	

$505



Test results	

8	

5	

40	

2	

4	

$1,904



Periodic reports	

4	

640	

2,560	

128	

256	

$121,871



TOTAL ANNUAL HOURS	

	

	

4,630	

234	

463	





TOTAL ANNUAL BURDEN	

	

	

5,327	

$220,560

See Attachment H for assumptions and further description of activities.

TABLE F-12:  AVERAGE ANNUAL EPA RESOURCE REQUIREMENT FOR SUBPART VVa

Activity	

(A)

EPA/hr Occurrence	

(B)

Occur-rences/

plant/yr	

(C)

Plants/ yr	

(D)a

Technical

hr/yr	

(E=F*.05)

Managerial hrs/yr	

(G=F*.10)

Clerical 

hrs/yr	

Cost/yre



Report Review: New Plant	

	

	

	

	

	

	





Notification of Construction	

8	

1	

23b	

184	

9	

18	

$8,739



Notification of Reconstruction/Modification	

2	

1	

15	

30	

2	

3	

$1,457



Notification of Actual Startup	

0.5	

1	

38	

19	

1	

2	

$910



Notification of Initial/Repeat Test	

0.5	

1	

46c	

23	

1	

2	

$1,079



Review Test Results	

2	

1	

46c	

92	

5	

9	

$4,398



Report Review: Existing Plant	

	

	

	

	

	

	





Semiannual Emission Reportse	

2.45	

2	

38d	

186	

9	

19	

$8,855



TOTAL ANNUAL HOURS	

	

	

	

534	

27	

53	





TOTAL ANNUAL BURDEN	

	

	

	

614	

$25,438

a D=AxBxC

b Estimate that there are 38 new affected sources each year over the
next three years (23 will be due to construction, and 15 will be
reconstructed or modified).  The estimate of 38 sources is based on
annual growth and reconstruction/modification being equal to 3% of the
estimated 1,272 existing sources.

c Assume 20 percent of performance tests are repeated due to failure
(7.6)

d There are an average of 38 new affected sources each year after
promulgation of VVa.  Assume that costs are being calculated for the 2nd
year in the three years after promulgation of VVa so that the 38 new
sources in the first year are existing sources in the second year.

 ADVANCE \u2 e Annual cost is the sum of costs for technical,
managerial, and clerical hours based on rates from the Office of
Personnel Management (OPM) “2006 General Schedule” which excludes
locality rates of pay.

Technical - $42.45 (GS-12, Step 1, $26.53 x 1.6)

Managerial - $57.20 (GS-13, Step 5, $35.75 x 1.6)

Clerical - $22.96 (GS-6, Step 3, $14.35 x 1.6).

ATTACHMENT G:  RESPONDENT BURDEN AND COST FOR REFERENCING SUBPARTS

	TABLE G-1:  ANNUAL BURDEN OF REPORTING AND RECORDKEEPING REQUIREMENTS
FOR SUBPART Kaa	

	

(A)

Hr/ Occurrence	

(B)

Occurrences/

plant/yr	

(C)a

Plants/yr	

(D) 

Technical 

hr/yr	

(E=D*.05)

Managerial 

hr/yr	

(F=D*.10)

Clerical

hr/yr ADVANCE \u2 	

(G)

Cost/yrb ADVANCE \d2 



1. Applications	

N/A	

	

	

	

	

	





2. Surveys and Studies	

N/A	

	

	

	

	

	





3. Reporting Requirements	

	

	

	

	

	

	





A. Read Instructions		

Included in 3B	

	

	

	

	

	





B. Required Activities	

	

	

	

	

	

	





Vapor recovery information	

20	

1	

0	

0	

0	

0	

$0



Measure seal gap	

Included in 4E	

	

	

	

	

	





C. Create Information	

Included in 3B	

	

	

	

	

	





D. Gather Existing  Information	

1	

1	

157c	

157	

8	

16	

$13,258



E. Write Report	

	

	

	

	

	

	





Notification of construction	

2	

1	

0	

0	

0	

0	

$0



Notification of actual startup	

2	

1	

0	

0	

0	

0	

$0



Notification of gap measurement	

1.5	

1	

188c	

282	

14	

28	

$23,741



Report of seal gap excess	

2.5	

1	

6d	

15	

1	

2	

$1,313



Information on vapor recovery	

Included in 3B	

	

	

	

	

	





Total Annual Responses (Block 13b)			

	

	

194	

	

	

	





4. Recordkeeping Requirements	

	

	

	

	

	

	





A. Read Instructions	

Included in 3B	

	

	

	

	

	





B. Plan Activities	

Included in 3B	

	

	

	

	

	





C. Implement Activities	

Included in 3B	

	

	

	

	

	





D. Develop Record

System	

N/A	

	

	

	

	

	





E. Time to Enter

Information	

	

	

	

	

	

	





New tank seal gap measurements	

250	

1	

0	

0	

0	

0	

$0



Secondary seal gap

measurement	

250d,e	

1	

157 ADVANCE \d2 c	

39,250	

1,963	

3,925	

$3,307,170



Primary seal gap measurements	

100d	

0.2f	

31c	

620	

31	

62	

$52,240



Fill/refill record	

2h	

1	

35g	

70	

4	

7	

$5,961



TOTAL ANNUAL HOURS	

	

	

	

40,394	

2,021	

4,040	





TOTAL ANNUAL BURDEN 	

	

	

	

46,455	

$3,403,683

a Assume that there will be no new source subject to the requirements of
this regulation.  Similar new sources will be subject to NSPS Subpart
Kb. There are 174 existing sources with an average of 50 tanks per
facility.  

b United States Department of Labor, Bureau of Labor Statistics, May
2006 National Industry-Specific Occupational Employment and Wage
Estimates, NAICS 325000 Chemical Manufacturing.  The wages are for
Environmental Engineers, General and Operations Managers, and Office and
Administrative Support Occupations.  The rates have been increased by
110 percent to account for the benefit packages available to those
employed by private industry.  Technical - $74.36/hr; Managerial -
$125.87/hr; Clerical - $36.04/hr.

c Estimate that 10 percent of respondents (17) will use a vapor recovery
control system, and 90 percent (157) will use a floating roof system. 
Respondents using vapor recovery control are not required to do seal gap
measurements.  All of the tanks using floating roof (157) will perform a
secondary seal gap measurement.  20 percent (31) will conduct a primary
seal gap measurement.  157 + 31 = 188 respondents submitting a
notification of either primary or secondary gap measurement.  

d Assume that 3 percent of respondents using a floating roof will have
excessive seal gaps (primary or secondary) requiring that a single
report be filed once a year.

e Estimate five hours to conduct secondary seal measurements annually
for the average 50 tanks per respondent.

f Estimate two hours to conduct primary seal measurements every five
years for the average 50 tanks per respondent.

g During any one year, a respondent would change liquid in approximately
20 percent of the facilities (35).

h Estimate 0.2 hours to record a liquid change per tank in 20 percent
(10) of the average of 50 tanks per facility. 

TABLE G-2:  ANNUAL BURDEN OF REPORTING AND RECORDKEEPING REQUIREMENTS
FOR SUBPART Kb

	

(A)

Hr/ Occurrence	

(B)

Occurrences/

plant/yr	

(C)a

Plants/ yr	

(D) 

Technical

 hr/yr	

(E=D*.05)

Managerial 

hr/yr	

(F=D*.10)

Clerical

hr/yr ADVANCE \d2 	

(G)

$

Cost/yr



1. Applications	

N/A	

	

	

	

	

	





2. Surveys and Studies	

N/A	

	

	

	

	

	





3. Reporting Requirements	

	

	

	

	

	

	





A. Read Instruction	

1	

1	

37 ADVANCE \u2 d ADVANCE \d2 	

37	

2	

4	

$3,147



B. Required Activities 	

	

	

	

	

	

	





One-Time Only Requirements

Notification of Start of Construction	

2	

1	

37	

74	

4	

7	

$6,258



Notification of Actual Startup	

2	

1	

37	

74	

4	

7	

$6,258



Notification of Physical or Operational Changes ADVANCE \u2 c ADVANCE
\d2 	

N/A	

	

	

	

	

	





Notification of Malfunction ADVANCE \u2 c ADVANCE \d2 	

N/A	

	

	

	

	

	





Notification of Initial Inspection	

	

	

	

	

	

	





IFR Internal Inspection	

2	

1	

28d	

56	

3	

6	

$4,758



EFR Gap Measurement	

2	

1	

7d	

14	

1	

1	

$1,203



Initial Inspection Report	

	

	

	

	

	

	





IFR Internal Inspection Report	

12	

1	

28d	

336	

17	

34	

$28,350



EFR 2nd Seal Gap Measurement	

8	

1	

7	

56	

3	

6	

$4,758



EFR 1st Seal Gap Measurement	

12	

1	

7	

84	

4	

8	

$7,038



CVS Operating Plan Report 	

8	

1	

2	

16	

1	

2	

$1,388



Repeat Requirements

Internal IFR Inspectione	

12	

1	

116	

1,392	

70	

139	

$117,330



Visual IFR Inspectione	

8	

1	

464	

3,712	

186	

371	

$312,807



Report of IFR Failuref	

2	

1	

55	

110	

6	

11	

$9,331



Notification of Delay of Repair or Emptying for IFRg	

4	

1	

6	

24	

1	

2	

$1,983



EFR 2nd Seal Gap Measure Report	

8	

1	

580	

4,640	

232	

464	

$390,955



EFR 1st Seal Gap Measure Report	

12	

1	

580	

6,960	

348	

696	

$586,432



Notification of Refillh	

2	

1	

602	

1,204	

60	

120	

$101,406



Number of Responses (Block 13b)	

	

	

1976	

	

	

	





4. Recordkeeping Requirements	

	

	

	

	

	

	





A. Read Instructions	

1	

1	

37	

37	

2	

4	

$3,147



B. Gather and Record Information	

 i.  Vessel Volumes, Liquid Vapor Pressure, flares	

8	

1	

580	

4,640	

232	

464	

$390,955



ii.  113b(a) inspection	

12	

1	

580	

6,960	

348	

696	

$586,432



iii. 113b(b) gap measurement		

12	

1	

580	

6,960	

348	

696	

$586,432



C. Develop Record System	

10	

1	

3	

30	

2	

3	

$2,591



D. Time to Enter Information - CVS Parameter Records	

2	

52	

355	

36,920	

1,846	

3,692	

$3,110,787



F. Train Personnel	

N/A	

	

	

	

	

	





G. Audits	

N/A	

	

	

	

	

	





TOTAL ANNUAL HOURS	

	

	

	

74,336	

3,720	

7,433	





TOTAL ANNUAL BURDEN	

	

	

	

85,489	

$6,263,746



a Estimate that there are 580 existing respondents with an average of
7,254 regulated vessels in service over the next three years.  Estimate
that 75 percent (5,468) of vessels have IFR, and 20 percent (1,458) have
EFR, and 5 percent (355) have closed-vent control  systems.  This does
not include sources subject to both  Subpart Kb and the HON, which are
assumed to be complying with the HON.

b United States Department of Labor, Bureau of Labor Statistics, May
2006 National Industry-Specific Occupational Employment and Wage
Estimates, NAICS 325000 Chemical Manufacturing.  The wages are for
Environmental Engineers, General and Operations Managers, and Office and
Administrative Support Occupations.  The rates have been increased by
110 percent to account for the benefit packages available to those
employed by private industry.  Technical - $74.36/hr; Managerial -
$125.87/hr; Clerical - $36.04/hr.

c The General Provision notifications of modification or malfunction
will be covered by notification within the subpart.

d Assume that there will be 37 new respondents each of the next three
years, which includes 28 IFRs, 7 EFRs, and 2 CVS.

e For each of the 5,468 IFRs at 580 respondents, 80 percent (464) will
conduct an annual visual inspection, and 20 percent (116) will conduct
an internal inspection.  These activities are required to generate the
information for the IFR failure report and the EFR primary and secondary
seal gap reports, but do not generate a response for the purposes of the
total for Block 13b.

f One percent failure rate for the 5468 IFRs choosing annual visual
inspections equals approximately 55.

g Ten percent of 55 failed IFRs are delayed in repair or emptying equals
approximately 6.

h Assume that all 5,468 IFR tanks will be routinely serviced through a
shutdown and degassed once every ten years.  One tenth of the 5468 IFRs
will be degassed each year, for an annual average of 547 per year.  This
number was added to the estimated 55 visual inspection failures that
would lead to internal inspections, for a total estimate of 602 notices
of refill.

TABLE G-3:  ANNUAL BURDEN OF REPORTING AND RECORDKEEPING REQUIREMENTS
FOR SUBPART VV

Activity	

(A)

Hr/

Occurrence	

(B)

Occurrences/

respondent/

yr	

(C)a

Respondents/ yr	

(D) 

Technical

 hr/yr	

(E=D*.05)

Managerial 

hr/yr	

(F=D*.10)

Clerical

hr/yr	

(G)

$

Cost/yr



1.	Applications	

N/A	

	

	

	

	

	





2.	Survey and Studies ADVANCE \d2 	

N/A	

	

	

	

	

	





3.	Reporting Requirements	

	

	

	

	

	

	





A. Read Instructions ADVANCE \d2 	

1	

1	

0	

0	

0	

0	

$0



B. Required Activities

Initial Performance Test Report	

48	

1	

0	

0	

0	

0	

$0



Repeat Performance Test Report	

48	

1	

0 ADVANCE \u2 c	

0	

0	

0	

$0



C. Create Information	

Included in 3B	

	

	

	

	

	





D. Gather Existing Information	

Included in 3E	

	

	

	

	

	





E. Write Report

New Sources

 Notification of Construction 	

2	

1	

0	

0	

0	

0	

$0



Notification of Reconstruction/ Modification	

2	

1	

0	

0	

0	

0	

$0



  Notification of Actual Startup	

2	

1	

0	

0	

0	

0	

$0



Notification of Initial/Repeat Performance Test	

2	

1	

0	

0	

0	

0	

$0



  Existing Sources Semiannual Report	

4	

2	

436	

3,488	

174	

349	

$293,847



Total Annual Responses	 (Block 13b)	

	

	

872	

	

	

	





4.	Recordkeeping Requirements	

	

	

	

	

	

	





A. Read Instructions	

Included in 3A	

	

	

	

	

	





B. Plan Activities	

Included in 4C	

	

	

	

	

	





C. Implement Activities	

Included in 3B	

	

	

	

	

	





D. Develop Record System	

N/A	

	

	

	

	

	





E. Time to Enter Information

Records of Operating Parameters	

80	

1	

436	

34,880	

1,744	

3,488	

$2,938,902



F. Train personnel	

N/A	

	

	

	

	

	





G. Audits	

N/A	

	

	

	

	

	





TOTAL ANNUAL HOURS	

	

	

	

38,368	

1,918	

3,837	





TOTAL ANNUAL BURDEN	

	

	

	

44,123	

$3,232,749

a All new sources will be subject to subpart VVa.  There are an average
of 436 existing sources per year for the next three years, based on the
assumption of 525 sources in the first and second year, and 258 in the
third year (when sources will become subject to the MON).  These sources
do not include those subject to both Subpart VV and the HON, which are
assumed to be complying with the HON.  See the footnote in Table F-3 for
the derivation of the estimated number of sources.

b United States Department of Labor, Bureau of Labor Statistics, May
2006 National Industry-Specific Occupational Employment and Wage
Estimates, NAICS 325000 Chemical Manufacturing.  The wages are for
Environmental Engineers, General and Operations Managers, and Office and
Administrative Support Occupations.  The rates have been increased by
110 percent to account for the benefit packages available to those
employed by private industry.  Technical - $74.36/hr; Managerial -
$125.87/hr; Clerical - $36.04/hr.

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

TABLE G-4:  ANNUAL BURDEN OF REPORTING AND RECORDKEEPING REQUIREMENTS
FOR SUBPART DDD

Activity	

(A)

Hr/ Occurrence	

(B)

Occurrences/

respondent/

yr	

(C) ADVANCE \u2 

Respondents/ yr	

(D) 

Technical 

hr/yra	

(E=D*.05)

Managerial 

hr/yr	

(F=D*.10)

Clerical

hr/yr	

(G)

$

Cost/yrb



1.	Applications	

N/A	

	

	

	

	

	





2.	Survey and Studies ADVANCE \d2 	

N/A	

	

	

	

	

	





3.	Reporting Requirements	

	

	

	

	

	

	





A. Read Instructions ADVANCE \d2 	

1	

1	

10 ADVANCE \u2 c	

10	

1	

1	

$906



B. Required Activities

Initial Performance Test Report	

360	

1	

10	

3,600	

180	

360	

$303,327



Repeat Performance Test Report	

360	

1	

2 ADVANCE \u2 d	

720	

36	

72	

$60,665



C. Write Report

Notification of Construction/ Modification	

2	

1	

10	

20	

1	

2	

$1,685



  Notification of Actual Startup	

1	

1	

10	

10	

1	

1	

$906



  Notification of Initial Performance Test	

2	

1	

10	

20	

1	

2	

$1,685



  Semiannual Report	

3	

2	

90 ADVANCE \u2 e	

540	

27	

54	

$45,499



Total Annual Responses 

(Block 13b)	

	

	

222	

	

	

	





4.	Recordkeeping Requirements	

	

	

	

	

	

	





Record of Operating Parameters for Control Devices	

1	

12	

10	

120	

6	

12	

$10,111



Records of Operating Conditions Exceeding Last Performance Test	

1	

8	

90	

720	

36	

72	

$60,665



Records of Startup, Shutdown, Malfunction, etc.	

0.25	

5	

90	

113	

6	

11	

$9,517



TOTAL ANNUAL HOURS	

	

	

	

5,873	

295	

587	





TOTAL ANNUAL BURDEN	

	

	

	

6,755	

$494,966

a D=AxBxC

b United States Department of Labor, Bureau of Labor Statistics, May
2006 National Industry-Specific Occupational Employment and Wage
Estimates, NAICS 325000 Chemical Manufacturing.  The wages are for
Environmental Engineers, General and Operations Managers, and Office and
Administrative Support Occupations.  The rates have been increased by
110 percent to account for the benefit packages available to those
employed by private industry.  Technical - $74.36/hr; Managerial -
$125.87/hr; Clerical - $36.04/hr.

c Assume 10 new affected sources per year.

d Assume 20 percent of performance tests are repeated due to failure.

e Average number of affected sources over next three years.

TABLE G-5:  ANNUAL BURDEN OF REPORTING AND RECORDKEEPING REQUIREMENTS
FOR SUBPART III

Activity	

(A)

Hr/ Occurrence	

(B)

Occurrences/

respondent/

yr	

(C) ADVANCE \u2 

Respondents/ yr	

(D) 

Technical 

hr/yra	

(E=D*.05)

Managerial 

hr/yr	

(F=D*.10)

Clerical

hr/yr	

(G)

$

Cost/yrb



1.	Applications	

N/A	

	

	

	

	

	





2.	Survey and Studies ADVANCE \d2 	

N/A	

	

	

	

	

	





3.	Reporting Requirements	

	

	

	

	

	

	





A. Read Instructions ADVANCE \d2 	

1	

1	

1 ADVANCE \u2 c	

1	

0	

0	

$74



B. Required Activities

Initial Performance Test Report	

60	

1	

1	

60	

3	

6	

$5,055



Repeat Performance Test Report	

60	

1	

0.2d	

12	

1	

1	

$1,054



C. Write Report

Notification of Construction/ Modification	

2	

1	

1	

2	

0	

0	

$149



  Notification of Actual Startup	

1	

1	

1	

1	

0	

0	

$74



  Notification of Initial Performance Test	

2	

1	

1	

2	

0	

0	

$149



  Semiannual Report	

3	

2	

11e	

66	

3	

7	

$5,538



Total Annual Responses 

(Block 13b)	

	

	

26	

	

	

	





4.	Recordkeeping Requirements	

	

	

	

	

	

	





Record of Operating Parameters for Control Devices	

1	

12	

1	

12	

1	

1	

$1,054



Records of Operating Conditions Exceeding Last Performance Test	

1	

8	

11	

88	

4	

9	

$7,372



Records of Startup, Shutdown, Malfunction, etc.	

0.25	

5	

11	

14	

1	

1	

$1,184



TOTAL ANNUAL HOURS	

	

	

	

258	

13	

25	





TOTAL ANNUAL BURDEN	

	

	

	

296	

$21,703

a D=AxBxC

b United States Department of Labor, Bureau of Labor Statistics, May
2006 National Industry-Specific Occupational Employment and Wage
Estimates, NAICS 325000 Chemical Manufacturing.  The wages are for
Environmental Engineers, General and Operations Managers, and Office and
Administrative Support Occupations.  The rates have been increased by
110 percent to account for the benefit packages available to those
employed by private industry.  Technical - $74.36/hr; Managerial -
$125.87/hr; Clerical - $36.04/hr.

c Assume 1 new affected source per year subject to Subpart III and not
the HON.

d Assume 20 percent of performance tests are repeated due to failure.

e Average number of affected sources over next three years.  This does
not include sources subject to both Subpart III and the HON, which are
assumed to be complying with the HON.

TABLE G-6:  ANNUAL BURDEN OF REPORTING AND RECORDKEEPING REQUIREMENTS
FOR SUBPART NNN

Activity	

(A)

Hr/ Occurrence	

(B)

Occurrences/

respondent/

yr	

(C) ADVANCE \u2 

Respondents/ yr	

(D) 

Technical 

hr/yra	

(E=D*.05)

Managerial 

hr/yr	

(F=D*.10)

Clerical

hr/yr	

(G)

$

Cost/yrb



1.	Applications	

N/A	

	

	

	

	

	





2.	Survey and Studies ADVANCE \d2 	

N/A	

	

	

	

	

	





3.	Reporting Requirements	

	

	

	

	

	

	





A. Read Instructions ADVANCE \d2 	

1	

1	

177c	

177	

9	

18	

$14,943



B. Required Activities

Initial Performance Test Report	

60	

1	

177	

10,620	

531	

1,062	

$894,815



Repeat Performance Test Report	

60	

1	

35d	

2,100	

105	

210	

$176,941



C. Write Report

Notification of Construction/ Modification	

2	

1	

177	

354	

18	

35	

$29,851



  Notification of Actual Startup	

1	

1	

177	

177	

9	

18	

$14,943



  Notification of Initial Performance Test	

2	

1	

177	

354	

18	

35	

$29,851



  Semiannual Report	

3	

2	

1345e	

8,070	

404	

807	

$680,021



Total Annual Responses 

(Block 13b)	

	

	

3,433	

	

	

	





4.	Recordkeeping Requirements	

	

	

	

	

	

	





Record of Operating Parameters for Control Devices	

1 ADVANCE \u2 	

12	

177	

2,124	

106	

212	

$178,923



Records of Operating Conditions Exceeding Last Performance Test	

1	

8	

1345	

10,760	

538	

1,076	

$906,611



Records of Startup, Shutdown, Malfunction, etc.	

0.25	

5	

1345	

1,681	

84	

168	

$141,646



TOTAL ANNUAL HOURS	

	

	

	

36,417	

1,822	

3,641	





TOTAL ANNUAL BURDEN	

	

	

	

41,880	

$3,068,545

a D=AxBxC

b United States Department of Labor, Bureau of Labor Statistics, May
2006 National Industry-Specific Occupational Employment and Wage
Estimates, NAICS 325000 Chemical Manufacturing.  The wages are for
Environmental Engineers, General and Operations Managers, and Office and
Administrative Support Occupations.  The rates have been increased by
110 percent to account for the benefit packages available to those
employed by private industry.  Technical - $74.36/hr; Managerial -
$125.87/hr; Clerical - $36.04/hr.

c Assume 177 new affected sources per year subject to Subpart NNN and
not the HON.

d Assume 20 percent of performance tests are repeated due to failure.

e Average number of affected sources over next three years.  This does
not include sources subject to both Subpart NNN and the HON, which are
assumed to be complying with the HON.

TABLE G-7:  ANNUAL BURDEN OF REPORTING AND RECORDKEEPING REQUIREMENTS
FOR SUBPART RRR

Activity	

(A)

Hr/ Occurrence	

(B)

Occurrences/

respondent/

yr	

(C) ADVANCE \u2 

Respondents/yr	

(D) 

Technical

 hr/yra	

(E=D*.05)

Managerial

hr/yr	

(F=D*.10)

Clerical

hr/yr	

(G)

$

Cost/yrb



1.	Applications	

N/A	

	

	

	

	

	





2.	Survey and Studies ADVANCE \d2 	

N/A	

	

	

	

	

	





3.	Reporting Requirements	

	

	

	

	

	

	





A. Read Instructions ADVANCE \d2 	

1	

1	

20c	

20	

1	

2	

$1,685



B. Required Activities

Initial Performance Test Report	

60	

1	

20	

1,200	

60	

120	

$101,109



Repeat Performance Test Report	

60	

1	

4d	

240	

12	

24	

$20,222



C. Write Report

Notification of Construction/ Modification	

2	

1	

20	

40	

2	

4	

$3,370



  Notification of Actual Startup	

1	

1	

20	

20	

1	

2	

$1,685



  Notification of Initial Performance Test	

2	

1	

20	

40	

2	

4	

$3,370



  Semiannual Report	

3	

2	

155e	

930	

47	

93	

$78,422



Total Annual Responses 

(Block 13b)	

	

	

394	

	

	

	





4.	Recordkeeping Requirements	

	

	

	

	

	

	





Record of Operating Parameters for Control Devices	

1	

12	

20	

240	

12	

24	

$20,222



Records of Operating Conditions Exceeding Last Performance Test	

1	

8	

155	

1,240	

62	

124	

$104,479



Records of Startup, Shutdown, Malfunction, etc.	

0.25	

5	

155	

194	

10	

19	

$16,351



TOTAL ANNUAL HOURS	

	

	

	

4,164	

209	

416	





TOTAL ANNUAL BURDEN	

	

	

	

4,789	

$350,915

a D=AxBxC

b United States Department of Labor, Bureau of Labor Statistics, May
2006 National Industry-Specific Occupational Employment and Wage
Estimates, NAICS 325000 Chemical Manufacturing.  The wages are for
Environmental Engineers, General and Operations Managers, and Office and
Administrative Support Occupations.  The rates have been increased by
110 percent to account for the benefit packages available to those
employed by private industry.  Technical - $74.36/hr; Managerial -
$125.87/hr; Clerical - $36.04/hr.

c Assume 20 new affected sources per year subject to Subpart RRR and not
the HON.

d Assume 20 percent of performance tests are repeated due to failure. 
(0.2 x 20 = 4)

e Average number of affected sources over next three years.  This does
not include sources subject to both Subpart RRR and the HON, which are
assumed to be complying with the HON.

TABLE G-8:  ANNUAL BURDEN OF REPORTING AND RECORDKEEPING REQUIREMENTS
FOR SUBPART BB

	

(A)

Hr/ Occurrence	

(B)

Occurrences/

Respondent/yr	

(C)a

Respondent/

yr	

(D) 

Technical 

hr/yr	

(E=D*.05)

Managerial

 hr/yr	

(F=D*.10)

Clerical

hr/yr	

(G) Cost/yrb 



1. Applications	

	

	

	

	

	

	





Application for approval of Construction/

Modification	

N/A	

	

	

	

	

	





2. Surveys and Studies	

N/A	

	

	

	

	

	





3. Reporting Requirements	

	

	

	

	

	

	





A. Read Instruction	

1	

1	

0	

0	

0	

0	

$0



B. Required Activities	

	

	

	

	

	

	





Initial emission test	

20	

0	

0	

0	

0	

0	

$0



Monitoring performance test	

280	

1	

0	

0	

0	

0	

$0



Vapor-tightness test tank truck and railcars	

11	

1	

3c	

33	

2	

3	

$2,814



Marine vessels	

80	

1	

66c	

5,280	

264	

528	

$444,880



Closed vent leak inspection	

8	

1	

54c	

432	

22	

43	

$36,442



C. Create Information	

Included in 3B	

	

	

	

	

	





D. Gather Existing Information	

Included in 3E	

	

	

	

	

	





E. Write Report	

	

	

	

	

	

	





Notification of anticipated startup	

2	

0	

0	

0	

0	

0	

$0



Notification of actual startup	

2	

0	

0	

0	

0	

0	

$0



Notification of emission test	

2	

0	

0	

0	

0	

0	

$0



Report of emission test	

8	

0	

0	

0	

0	

0	

$0



Notification of performance test ADVANCE \d2 	

2	

0	

0	

0	

0	

0	

$0



Report of performance test	

8	

0	

0	

0	

0	

0	

$0



Report facilities below cut-offd	

8	

0	

0	

0	

0	

0	

$0



Quarterly parameter excesses	

4 ADVANCE \d2 	

4	

54	

864	

43	

86	

$72,759



Total Annual Responses 

(Block 13b)	

	

	

216	

	

	

	





SUBTOTAL	

	

	

	

	

	

	





4. Recordkeeping 

Requirements	

	

	

	

	

	

	





A. Read Instructions	

Included in 3A	

	

	

	

	

	





B. Plan Activities	

Included in 4C	

	

	

	

	

	





C. Implement Activities	

Included in 3B	

	

	

	

	

	





D. Develop Record

System	

N/A	

	

	

	

	

	





E. Time to Enter

Information	

	

	

	

	

	

	





  i. Facilities above cut-off	

1.5 ADVANCE \d2 	

52	

54	

4,212	

211	

421	

$354,936



  ii. Facilities below cut-offd	

0.5	

52	

0	

0	

0	

0	

$0



F. Train Personnel	

N/A	

	

	

	

	

	





G. Audits	

N/A	

	

	

	

	

	





TOTAL ANNUAL HOURS	

	

	

	

10,821	

542	

1,081	





TOTAL ANNUAL BURDEN	

	

	

	

12,444

	

$911,831

a Expect that there will be no new sources covered by these standards
over the next three years.

b United States Department of Labor, Bureau of Labor Statistics, May
2006 National Industry-Specific Occupational Employment and Wage
Estimates, NAICS 325000 Chemical Manufacturing.  The wages are for
Environmental Engineers, General and Operations Managers, and Office and
Administrative Support Occupations.  The rates have been increased by
110 percent to account for the benefit packages available to those
employed by private industry.  Technical - $74.36/hr; Managerial -
$125.87/hr; Clerical - $36.04/hr.

c Estimate that there are 54 facilities subject to this standard. 
Estimate there are 3 tank truck and railcars and 131 marine vessels
subject  to the standards.  All other transfer racks subject to Subpart
BB are assumed to be complying with the HON.  Assume 50 percent of the
marine vessels (66) operate at negative pressure and do not conduct
annual vapor-tightness tests.

d For sources below the low quantity applicability for control
requirements, a report is only required the first year of operation.  It
is assumed that this report has been submitted.

TABLE G-9:  ANNUAL BURDEN OF REPORTING AND RECORDKEEPING REQUIREMENTS
FOR SUBPART Y

	

(A)

Hr/ Occurrence	

(B)

Occurrences/

Respondent/yr	

(C)a

Respondent/

yr	

(D) 

Technical 

hr/yr	

(E=D*.05)

Managerial

 hr/yr	

(F=D*.10)

Clerical

hr/yr	

(G)

Cost/ yrb



1. Applications	

	

	

	

	

	

	





Application for approval of Construction/Modification	

N/A	

	

	

	

	

	





2. Surveys and Studies	

N/A	

	

	

	

	

	





3. Reporting Requirements	

	

	

	

	

	

	





A. Read Instructions			

Included in 3C	

	

	

	

	

	





B. Required Activities	

	

	

	

	

	

	





Initial performance test	

N/A	

	

	

	

	

	





C. Create Information	

		

	

	

	

	

	





Annual IFR Internal

Inspections and EFR

Seal Gap measurements (existing sources)	

8

	

1	

4	

32	

2	

3	

$2,739



D. Gather Existing Information	

Included in 3C	

	

	

	

	

	





E. Write Report	

	

	

	

	

	

	





New Sources	

	

	

	

	

	

	





  Notification of Construction/Reconstruction	

Included in NSPS Kb	

	

	

	

	

	





Notification of anticipated startup	

Included in NSPS Kb	

	

	

	

	

	





Notification of actual startup	

Included in NSPS Kb	

	

	

	

	

	





Notification of emission test	

N/A	

	

	

	

	

	





Report of emission test	

N/A	

	

	

	

	

	





Notification of Control

installation and refill at

1st IFR Degassingc	

2	

1	

0	

0	

0	

0	

$0



Existing Sources	

	

	

	

	

	

	





Annual Inspection Reports	

2	

2	

4	

16	

1	

2	

$1,388



Supplemental Delay Reportd	

2	

1	

0	

0	

0	

0	

$0



Quarterly Emission Report	

None Expectede	

	

	

	

	

	





Total Annual Responses (Block 13b)	

	

	

8	

	

	

	





4. Recordkeeping

Requirements	

	

	

	

	

	

	





A. Read Instructions	

Included in 3A	

	

	

	

	

	





B. Plan Activities	

Included in 4C	

	

	

	

	

	





C. Implement Activities -

Filing and Maintaining Records	

	2	

1	

4	

8	

0	

1	

$631



D. Develop Record System	

Included in 4C	

	

	

	

	

	





  E. Time to Enter Information	

Included in 4C	

	

	

	

	

	





F. Train Personnel	

N/A	

	

	

	

	

	





G. Audits	

N/A	

	

	

	

	

	





TOTAL ANNUAL HOURS	

	

	

	

56	

3	

6	





TOTAL ANNUAL BURDEN	

	

	

	

65	

$4,758

a Estimate that there will be 4 existing sources not covered by the HON.
 All new source burden is included in the NSPS Subpart Kb regulation for
storage vessels at 40 CFR Part 60

b United States Department of Labor, Bureau of Labor Statistics, May
2006 National Industry-Specific Occupational Employment and Wage
Estimates, NAICS 325000 Chemical Manufacturing.  The wages are for
Environmental Engineers, General and Operations Managers, and Office and
Administrative Support Occupations.  The rates have been increased by
110 percent to account for the benefit packages available to those
employed by private industry.  Technical - $74.36/hr; Managerial -
$125.87/hr; Clerical - $36.04/hr.

c It is believed that all vessels have been degassed and all controls
have been installed as they were to be installed within 10 years of
promulgation.

d Estimate that two percent of existing sources will request delay of
repair in the annual report.

e Assume that no sources will select the fixed roof vented to a control
device option and, thus, have no quarterly reports of excess emissions.

TABLE G-10:  ANNUAL BURDEN OF REPORTING AND RECORDKEEPING REQUIREMENTS
FOR SUBPART V

Activity	

(A)

Hr/

Occurrence	

(B)

Occurrences/

respondent/

yr	

(C) ADVANCE \u2 

Respondents/ yr	

(D) 

Technical 

hr/yr	

(E=D*.05)

Managerial

 hr/yr	

(F=D*.10)

Clerical

hr/yr	

(G)a

Cost/yr



1.	Applications	

N/A	

	

	

	

	

	





2.	Survey and Studies ADVANCE \d2 	

N/A	

	

	

	

	

	





3.	Reporting Requirements	

	

	

	

	

	

	





A. Read Instructions ADVANCE \d2 	

1	

1	

2b	

2	

0	

0	

$149



B. Required Activities

Initial Performance Test	

20	

1	

2	

40	

2	

4	

$3,370



Reference Method 21/22 Tests	

4	

1	

2	

8	

0	

1	

$631



Repeat Performance Test	

20	

0.2	

2	

8	

0	

1	

$631



C. Create Information	

See 3B	

	

	

	

	

	





D. Gather Existing Information	

See 3B	

	

	

	

	

	





E. Write Report

Notification of Construction/ Reconstruction	

2	

1	

2	

4	

0	

0	

$297



Notification of Anticipated Startup	

2	

1	

2	

4	

0	

0	

$297



  Notification of Actual Startup	

2	

1	

2	

4	

0	

0	

$297



  Notification of Initial Performance Test	

2	

1	

2	

4	

0	

0	

$297



Report of Performance Test	

See 3B	

	

	

	

	

	

$0



Application for Alternative	

10	

1	

0.5	

5	

0	

1	

$408



Initial Report	

8	

1	

2	

16	

1	

2	

$1,388



  Semiannual Report	

30	

2	

55c	

3,300	

165	

330	

$278,050



Total Annual Responses (Block 13b)	

	

	

123	

	

	

	





4.	Recordkeeping Requirements	

	

	

	

	

	

	





A. Read Instructions	

See 3A	

	

	

	

	

	





B. Plan Activities	

See 4C	

	

	

	

	

	





C. Implement Activities	

See 3B	

	

	

	

	

	





D. Develop Record System	

N/A	

	

	

	

	

	





E. Time to Enter Information

Records of startups, shutdown, malfunction, etc.	

1.5	

1	

2	

3	

0	

0	

$223



Records of operating, parameters and emissions	

0.1	

365d	

55c	

2,008	

100	

201	

$169,109



Records of leak detected	

0.4	

52	

55	

1,144	

57	

114	

$96,351



F. Train personnel	

N/A	

	

	

	

	

	





G. Audits	

N/A	

	

	

	

	

	





TOTAL ANNUAL HOURS	

	

	

	

6,550	

325	

654	





TOTAL ANNUAL BURDEN	

	

	

	

7,529	

$551,498

a United States Department of Labor, Bureau of Labor Statistics, May
2006 National Industry-Specific Occupational Employment and Wage
Estimates, NAICS 325000 Chemical Manufacturing.  The wages are for
Environmental Engineers, General and Operations Managers, and Office and
Administrative Support Occupations.  The rates have been increased by
110 percent to account for the benefit packages available to those
employed by private industry.  Technical - $74.36/hr; Managerial -
$125.87/hr; Clerical - $36.04/hr.

b Assume one new facility per year comprising two new sources.

c Estimate 21 existing facilities comprising 55 sources.

TABLE G-11:  NEW SOURCE ANNUAL RESPONDENT BURDEN AND COST OF REPORTING
AND 

RECORDKEEPING REQUIREMENTS OF THE HON

Burden Item	

Average Hours per Activity

(a)	

Number of Activities per year per respondent

(b)	

Technical Hours per year per respondent

(c)	

Estimated. Number New respondents

(d)	

Estimated Technical Hours per year

(e)	

Estimated Managerial Hours per year

(f)	

Estimated Clerical Hours per year

(g)	

Annual Cost per year

(h)



1) Read Rule and Instructions	

2.7	

93	

250	

5	

1,250	

63	

125	

$105,385



2) Plan Activities	

3.8	

93	

355	

5	

1,775	

89	

178	

$149,607



3) Training	

3.5	

38	

132	

5	

660	

33	

66	

$55,610



4) Create, Test, Research and Development	

2.4	

1,778	

4,266	

5	

21,330	

1,067	

2,133	

$1,797,275



5) Gather Information, 	Monitor/Inspect	

1.4	

2,102	

2,943	

5	

14,715	

736	

1,472	

$1,239,899



6) Process/Compile and Review	

0.8	

50	

40	

5	

200	

10	

20	

$16,852



7) Complete Reports	

11.4	

49	

557	

5	

2,785	

139	

279	

$234,644



Total Annual Responses (Block 13b)	

	

	

	

245	

	

	

	





8) Record/Disclose	

10.0	

49	

489	

5	

2,445	

122	

245	

$205,996



9) Store/File	

5.2	

51	

264	

5	

1,320	

66	

132	

$111,220



TOTAL ANNUAL HOURS	

	

	

	

	

46,480	

2,325	

4,650	





TOTAL ANNUAL BURDEN	

	

	

	

	

53,455	

$3,916,488

(a) = (c)/(b)

(d) - From previously approved ICR. 

See Attachment I for assumptions and further description of activities.

TABLE G-12:  EXISTING SOURCE ANNUAL RESPONDENT BURDEN AND COST OF
REPORTING AND 

RECORDKEEPING REQUIREMENTS OF THE HON PROVISIONS

Burden Item	

Average Hours per Activity

(a)	

Number of Activities per year per respondent

(b)	

Total Technical Hours per year per respondent

(c)	

Technical Hours per year per respondent for wastewater

(d)	

Estimated Technical Hours per year

(e) 	

Estimated Managerial Hours per year

(f)	

Estimated Clerical Hours per year

(g)	

Annual Cost

 $per year

(h)



1) Read Rule and Instructions	

3.6	

23	

69	

14	

17,680	

884	

1,768	

$1,489,673



2) Plan Activities	

6.1	

13	

61	

18	

16,080	

804	

1,608	

$1,354,861



3) Training	

5.3	

4	

17	

4	

4,400	

220	

440	

$370,733



4) Create, Test, Research and Development	

17.8	

99	

1617	

150	

400,080	

20,004	

40,008	

$33,709,741



5) Gather Information, Monitor/Inspect	

2.5	

677	

1693	

0	

406,320	

20,316	

40,632	

$34,235,507



6) Process/Compile and Review	

20.0	

1	

20	

0	

4,800	

240	

480	

$404,436



7) Complete Reports	

81.2	

5	

388	

18	

94,560	

4,728	

9,456	

$7,967,389



Total Annual Responses (Block 13b)a	

	

	

	

1,600	

	

	

	





8) Record/Disclose	

17.5	

26	

442	

12	

107,040	

5,352	

10,704	

$9,018,923



9) Store/File	

6.8	

35	

222	

15	

54,480	

2,724	

5,448	

$4,590,349



TOTAL ANNUAL HOURS	

	

	

	

	

1,105,440	

55,272	

110,544	





TOTAL ANNUAL BURDEN	

	

	

	

	

1,271,256	

$93,141,612

(a) = (c + d)/(b)

(c) - there are 240 existing sources out of the 320 total that will
continue to comply with the HON.  

(d) - the 80 facilities complying with the CAR will still be required to
comply with the HON for wastewater. 

a Total number of respondents is 320 (240 for HON + 80 CAR still
complying with HON Wastewater).

See Attachment I for assumptions and further description of activities.

TABLE G-13:  ANNUAL BURDEN OF REPORTING AND RECORDKEEPING REQUIREMENTS
FOR SUBPART VVa

Activity	

(A)

Hours/

Occurrence	

(B)

Occurrences/

respondent/

yr	

(C)a

Respondents/ yr	

(D) 

Technical

 hr/yr	

(E=D*.05)

Managerial 

hr/yr	

(F=D*.10)

Clerical

hr/yr	

(G)

$

Cost/yrb



1.	Applications	

N/A	

	

	

	

	

	





2.	Survey and Studies ADVANCE \d2 	

N/A	

	

	

	

	

	





3.	Reporting Requirements	

	

	

	

	

	

	





A. Read Instructions ADVANCE \d2 	

1	

1	

38	

38	

2	

4	

$3,222



B. Required Activities

Initial Performance Test Report	

48	

1	

38	

1,824	

91	

182	

$153,646



Repeat Performance Test Report	

48	

1	

8 ADVANCE \u2 c	

384	

19	

38	

$32,315





C. Create Information	

Included in 3B	

	

	

	

	

	





D. Gather Existing Information	

Included in 3E	

	

	

	

	

	





E. Write Report

New Sources

 Notification of Construction 	

2	

1	

23	

46	

2	

5	

$3,853



Notification of Reconstruction/ Modification	

2	

1	

15	

30	

2	

3	

$2,591



  Notification of Actual Startup	

2	

1	

38	

76	

4	

8	

$6,443



Notification of Initial/Repeat Performance Test	

2	

1	

46	

92	

5	

9	

$7,795



  Existing Sources Semiannual Report	

4.5	

2	

38	

342	

17	

34	

$28,796



Total Annual Responses (Block 13b)	

	

	

244	

	

	

	





4.	Recordkeeping Requirements

A. Read Instructions	

Included in 3A	

	

	

	

	

	





B. Plan Activities	

Included in 4C	

	

	

	

	

	





C. Implement Activities	

Included in 3B	

	

	

	

	

	





D. Develop Record System	

N/A	

	

	

	

	

	





E. Time to Enter Informationd	

	

	

	

	

	

	





Average Facilities - Records of Operating Parameters	

89.5	

1	

34	

3,043	

152	

304	

$256,366



Small Facilities - Records of Operating Parameters	

95.2	

1	

4	

381	

19	

38	

$32,077



F. Train personnel	

N/A	

	

	

	

	

	





G. Audits	

N/A	

	

	

	

	

	





TOTAL ANNUAL HOURS	

	

	

	

6,256	

313	

625	





TOTAL ANNUAL BURDEN	

	

	

	

7,146	

$527,104

a Assume that there will be an average 38 new, modified, or
reconstructed facilities each year over the next 3 years.  Estimate that
23 of new affected sources will be due to construction, and 15 will be
reconstructed or modified.  There are an average of 38 new affected
sources each year after promulgation of VVa.  Assume 10 percent are
small facilities that will record instrument readings manually, and 90
percent of facilities use automated equipment to capture instrument
readings electronically.  Assume that costs are being calculated for the
second of the three years after promulgation of VVa, so that the 38 new
sources in the first year are existing sources in the second year. 
Since subpart VVa is more stringent than the HON and MON, no sources are
assumed to be complying with the HON or MON instead of subpart VVa.

b United States Department of Labor, Bureau of Labor Statistics, May
2006 National Industry-Specific Occupational Employment and Wage
Estimates, NAICS 325000 Chemical Manufacturing.  The rates are for
General and Operations Managers, Environmental Engineers, and Office and
Administrative Support Occupations.  The rates have been increased by
110 percent to account for the benefit packages available to those
employed by private industry.  Technical - $74.36/hr; Managerial -
$125.87/hr; Clerical - $36.04/hr.

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

d Details of the additional hours relative to the hours for a source
subject to subpart VV are provided in section 6(f) of Part A of the
Supporting Statement.



Attachment H

Assumptions and Item Descriptions for Attachment F:  Table F-11

(A) That all existing and new sources must submit an initial report
within 120 days of promulgation and an implementation plan or permit
application within 12 or 18 months of the compliance date.  It is
assumed that initial reports and implementation plans have been
submitted for existing sources and these reports are only required for
new sources.  The new sources are most likely to be collocated within
existing plants and be included in those existing source reports.

(B) That semiannual reports of results from equipment leak detection and
repair programs are required by the equipment leak standard.  Sources
are required to comply with the equipment leak standard by 6 months
after promulgation.  It is assumed that an average of 320 facilities
will submit reports semiannually (320 x 2 = 640) (even those that use
the CAR will still have to submit reports under the HON for wastewater).

Item Descriptions:

(a) Average Hours per Activity are estimates of the specific activities
and are the basis for estimating the overall burden.

(b) Number of Activities per year represents the number of reports
expected to be reviewed and other related activities during the course
of the year.  Under the performance test headings, these numbers are
based upon assumptions (A) and (B), above.  For one-time reports, the
total number of reports expected over the three-year period was divided
by three to get an annual average incorporating assumption (C), above.

(c) Estimated Technical Hours per year is the product of (a) and (b).

(d) Estimated Managerial Hours per year is 5 percent of (c).

(e) Estimated Clerical Hours per year is 10 percent of (c).

(f) Estimated Annual Cost per year is the sum of costs for technical,
managerial, and clerical hours based on rates from the Office of
Personnel Management (OPM) “2006 General Schedule” which excludes
locality rates of pay.

Technical - $42.45 (GS-12, Step 1, $26.53 x 1.6)

Managerial - $57.20 (GS-13, Step 5, $35.75 x 1.6)

Clerical - $22.96 (GS-6, Step 3, $14.35 x 1.6)

(Ht x $42.45/hour)+(Hm x $57.20/hour)+(Hc x $14.35/hour) = (G)

Where:

Ht is (c), or technical hours

Hm is (d), or managerial hours, and

Hc is (e), clerical hours

Report Review:

1) Initial represents the EPA review of all initial reports received.

2) Implementation Plan or Permit Applications represents the EPA review
of all implementation plans, or permit applications if submitted in lieu
of an implementation plan.

3) Compliance Status represents compliance status verification by the
EPA for the portions of the standard which a source must comply with
before the compliance date (see assumption (D) above).

4) Review equipment leak monitoring represents the review and screening
of periodic reports received as a result of the equipment leaks
standard.

5) Notification of construction/reconstruction represents the EPA review
of this notification from new sources.

6) Notification of anticipated startup represents the EPA review of this
notification from new sources.

7) Notification of actual startup represents the EPA review of this
notification from new sources.

8) Notification of performance test represents the EPA review of this
notification from new sources.

9) Review of test results represents the EPA review of performance test
results for new sources.

10) Review periodic reports represents the EPA review of periodic
reports.

TOTAL BURDEN AND COST is the sum of each of the columns (d), (e), (f)
and (g).

Attachment I

Assumptions and Item Descriptions for Attachment G:  Tables G-11 and
G-12

Assumptions are:

(A) That there are 240 existing facilities out of 320 that will continue
to comply with the HON, rather than the CAR.  The 80 facilities
complying with the CAR will still be required to comply with the HON
wastewater provisions, as the CAR does not include wastewater
provisions.  The total number of facilities will increase by 5 new
facilities per year.  Since new facilities must be in compliance at
startup, the general periodic recordkeeping and reporting burdens are
included, which accounts for the difference in the technical hours per
facility.  No new facilities are expected to comply directly with the
CAR.

(B) That the average representative source, new and existing, will
consist of the following points of burden:

20 parameters to monitor at control devices throughout the facility

10 affected storage tanks of various capacities

3 affected major wastewater streams

4 affected transfer rack operations

3 overall leak detection and repair programs for 2,000 points

1 emissions averaging program that involves 10 emission points

1 facility wide inventory of emission points, Group 1 and Group 2

8 process vents per facility

(C) That there are 5 percent (0.05) managerial and 10 percent (0.10)
clerical hours required for every technical hour.

(D) That some activities necessary to generate reports involve creating
records in the process, and that these activities are assumed to be
reports activities alone, to avoid double counting these as records
activities as well.  Therefore, only items 8 and 9 are considered
records burdens directly.

Item Descriptions:

(a) Average Hours per Activity is back-calculated by dividing (b) into
(c).  Since the activities within each burden category can vary
significantly, it is too inaccurate to assume an average to use to
calculate (c).  Estimated activity technical hours are summarized to
obtain (c) first, then back calculate for (a) with an estimated (b).

(b) Estimated Number of Activities per year per source represents the
assumed typical number of separate activities a source may encounter
during one year.  This number may vary from facility to facility,
depending on consolidation of activities, collocated readings, etc. 
Since so much variability exists, it is important to note that this is
an estimate.  This number was only used to back-calculate (a).

(c) Technical Hours per year per source is the actual best estimate of
the burden for each burden item.  The three-year separate activity
burdens were divided by three, where appropriate, and then summarized to
include in this column.  The technical hours for new sources is higher
because some periodic compliance reports and records are required at
startup.  Existing sources do not encounter these reports and record
burdens for three years after promulgation.

(d) (Table G-11) Estimated Number of New Sources reflect the number
given in assumption (A), above.  (Table G-12) Technical Hours Per Year
Per Source for Wastewater are the annual technical hours associated with
recordkeeping and reporting to ensure compliance with requirements for
wastewater.  As discussed in assumption (A), facilities complying with
the CAR will comply with the HON wastewater requirements.  Burden hours
per source, per emission type are shown in Table B-1.

(e) Estimated Technical Hours per year is the product of (c) and (d) for
new facilities (Table G-11).  For Table G-12, estimated technical hours
are the product of (c) and the number of existing facilities complying
with all of the HON (240) added to the product of (d) and the number of
facilities complying with only the wastewater provisions (80).

(f) Estimated Managerial Hours per year is 5 percent of (e).

(g) Estimated Clerical Hours per year is 10 percent of (e).

(h) Estimated Annual Cost per year is from the United States Department
of Labor, Bureau of Labor Statistics, May 2006 National
Industry-Specific Occupational Employment and Wage Estimates, NAICS
325000 Chemical Manufacturing.  The rates are for General and Operations
Managers, Environmental Engineers, and Office and Administrative Support
Occupations.  The rates have been increased by 110 percent to account
for the benefit packages available to those employed by private
industry.

(Ht x $74.36/hour)+(Hm x $125.87/hour)+(Hc x $36.04/hour) = (G)

Where:

Ht is (e), or technical hours

Hm is (f), or managerial hours, and

Hc is (g), clerical hours

1) Read Rule and Instructions are the activities, less training, which
involve comprehending the provisions in the standard and understanding
how they apply to the respective points at a facility.

  2) Plan Activities represents such burdens as design, redesign,
scheduling as well as drafting the implementation plan, and selecting
methods of compliance.

3) Training represents the portion (assumed 40 percent) of activities
from 1) Read Rule and Instruction for which an average facility would
elect to provide class room instruction.  The standard does not require
specific training itself.

4) Create, Test, Research and Development are the activities involving
testing, retesting, establishing operating range for parameters and
analyzing point by point applicability.  Monitor related refit,
calibration and maintenance activities are also included under this
heading.

5) Gather Information, Monitor and Inspect are the activities involving
physical inspections of equipment, collection of monitored data and
other related activities.

6) Process/Compile and Review are the activities that involve analysis
of the information collected for accuracy, compliance, and appropriate
reports and records required as a result.

7) Complete Reports represents the activities normally associated with
filling out forms.  Since the standard requires no standard forms, these
activities relate to the preparing of formal reports and cover letters
as appropriate.

8) Record/Disclose are activities which are solely recordkeeping which
occur once the appropriate report information has been extracted [see
assumption (D)] above.  These activities involve software translation,
duplication, or archival processes normally associated with data
management and storage common to this industry.

9) Store/File are again activities which are solely recordkeeping which
occur once the appropriate report information has been extracted (see
assumption (D) above).  These activities involve the management life
cycle of records, from the time they are filed and boxed up, to the time
they are disposed.

TOTAL BURDEN AND COST is the sum of each of the columns (e), (f), (g)
and (h).

Attachment J

Summary of Capital/Startup and Operation and Maintenance Costs for the
CAR and the Referencing Subparts

NSPS Subpart Ka

a.	Total Capital/Startup Cost of Monitoring Equipment:

The total Capital/Start-up costs for this ICR are $0.

b.	Total Cost of Operation and Maintenance of Monitoring Equipment:

The total Operating and Maintenance (O&M) Costs for this ICR is $0.

c.	Total Capital/Startup and O&M Cost:

The total Capital and O&M Costs are $0.

NSPS Subpart Kb

a.	Total Capital/Startup Cost of Monitoring Equipment:

The total Capital/Start-up costs for this ICR are $27,000.  This is the
cost for 2 new storage tanks to install monitoring equipment associated
with the CVS routed to a control device. The storage tanks will use
equipment similar to that used for subparts NNN and III; therefore, the
startup costs are approximately $13,500 per facility for a total of
$27,000.  There are no capital/startup costs for the remaining 35 new
storage tanks complying by either an IFR or EFR.  

b. 	Total Cost of Operation and Maintenance of Monitoring Equipment:

 The average annualized burden is estimated to be $1,350 per year per
affected facility ($13,500 discounted over 10 years by straight line
depreciation method) for both new and existing affected sources using
CVS to a control device (31), for a total of $41,850.

c.	Total Capital/Startup and O&M Cost:

The total Capital and O&M Costs are $68,850.

NSPS Subpart VV

a.	Total Capital/Startup Cost of Monitoring Equipment:

The capital/startup costs of this regulation are $0.  It is assumed that
facilities that are already complying with subpart VV will not need to
buy an additional monitor and no additional facilities will become
subject to subpart VV in the future.

b.	Total Cost of Operation and Maintenance of Monitoring Equipment:

The operation of the monitors is included in the monitoring costs. 
Maintenance costs on these units is incidental, therefore no maintenance
or operation costs incur.

c.	Total Capital/Startup and O&M Cost:

The total Capital and O&M Costs are $0.

NSPS Subpart VVa

a.	Total Capital/Startup Cost of Monitoring Equipment:

The capital/startup costs of this regulation are $4,200.  This is based
on the average cost of a monitor ($7,000) with a 5-year expected life. 
The equipment is not capitalized, so no discount rate applies.  The
average annual cost is, therefore, $7,000/5, or $1,400/yr.  It is
estimated that only area sources that construct new process units might
purchase a monitoring instrument.  All other sources should have
monitoring equipment because they are either subject to MACT rules or
have been subject to NSPS subpart VV for other processes.  Assuming that
38 process units are subject to NSPS subpart VVa each year, 60 percent
of new sources are newly constructed sources, and that 15 percent of all
new sources are area sources, an estimated 3 facilities with a new
process unit will buy a monitoring instrument to comply with NSPS
subpart VVa.

b.	Total Cost of Operation and Maintenance of Monitoring Equipment:

The operation of the monitors is included in the monitoring costs. 
Maintenance costs on these units is incidental; therefore, no
maintenance or operation costs incur.

c.	Total Capital/Startup and O&M Cost:

The total Capital and O&M Costs are $4,200.

NSPS Subpart DDD

a. 	Total Capital/Startup cost of Monitoring Equipment:

The capital/startup costs for this regulation are $300,000.  This is
based on 10 new sources per year multiplied by $30,000 per source for
monitoring equipment. 

b.	Total Cost of Operation and Maintenance of Monitoring Equipment:

The annual operation and maintenance costs are $630,000 dollars.  This
is based on 80 existing sources plus 10 new sources over the life of the
ICR multiplied by $7,000 for upkeep of the monitoring devices.

c.	Total Capital/Startup and O&M Cost:

The total Capital and O&M Costs are $930,000.

NSPS Subpart NNN/III

a.	Total Capital/Startup Cost of Monitoring Equipment:

The startup cost of monitoring equipment is approximately $13,500 per
new affected facility for both Subpart III, Air Oxidation Operations and
Subpart NNN, Distillation Operations, or a total of $2,403,000 (total of
178 new sources x $13,500/source).

b.	Total Cost of Operation and Maintenance of Monitoring Equipment:

The average annualized burden is estimated to be $1,350 per year per
affected facility ($13,500 discounted over 10 years by straight line
depreciation method) for Subpart III and for Subpart NNN for a total of
$1,830,600 [($1,350 x 1,356) total number of new and existing affected
sources under NNN and III].  

c.	Total Capital/Startup and O&M Cost:

The total Capital and O&M Costs are $4,233,600.

NSPS Subpart RRR

a.	Total Capital/Startup cost of Monitoring Equipment:

The capital/startup costs for this regulation are $500,000 dollars per
year.  This is based on 20 new sources per year multiplied by $25,000
for monitoring equipment discounted over 10 years at 7 percent. 

b.	Total Cost of Operation and Maintenance of Monitoring Equipment:

The annual operation and maintenance costs are $77,500 dollars.  This is
based on 155 existing sources multiplied by $500 for upkeep of the
monitoring device.

c.	Total Capital/Startup and O&M Cost:

The total Capital/startup and O&M Costs are $577,500.

NESHAP Subpart BB

a.	Total Capital/Startup cost of Monitoring Equipment:

Startup cost were identified in previous ICR.

b.	Total Cost of Operation and Maintenance of Monitoring Equipment:

There are no O&M cost associated because no CEMs are employed.

c.	Total Capital/Startup and O&M Cost:

The total Capital and O&M Costs are $0.

NESHAP Subpart Y

a.	Total Capital/Startup Cost of Monitoring Equipment:

The only type of industry costs associated with the information
collection activity in the standards is labor cost.  There are no
capital/startup costs. 

b.	Total Cost of Operation and Maintenance of Monitoring Equipment:

There are no operation and maintenance costs. 

c.	Total Capital/Startup and O&M Cost:

The total Capital and O&M Costs are $0.

NESHAP Subpart V

a.	Total Capital/Startup Cost of Monitoring Equipment:

Startup cost were identified in previous ICR.

b.	Total Cost of Operation and Maintenance of Monitoring Equipment:

There are no O&M costs associated because no CEMs are employed.

c.	Total Capital and O&M Cost

The total Capital and O&M Costs are $0.

NESHAP HON:

Subpart G

a.	Total Capital/Startup Cost of Monitoring Equipment:

Estimate the cost to purchase monitoring equipment is approximately
$20-30K for process vents and wastewater operations, or an average of
$25K with a 10-year life expectancy and a 7 percent depreciation rate,
or $2225 per year.  There are no associated costs for transfer racks and
storage tanks.  Only new sources need to buy monitoring equipment;
therefore, the total capital/startup cost is $25,000 x 5, or $125,000.

b.	Total Cost of Operation and Maintenance of Monitoring Equipment:

The cost to industry associated with the operation and maintenance (O&M)
is approximately $100-500K per year (capital/startup depreciation not
included) for reactor process vents and wastewater operations.  The cost
associated with the operation and maintenance is $50-100K per year
(capital/startup depreciation not included) for distillation units
process vents.  There are no associated costs for transfer racks and
storage tanks.  The average O&M cost is assumed to be the average of the
two ranges, or $275,000 per year.  Operation and maintenance incur for
both new and existing sources.  The total O&M is, therefore, $275,000 x
245, or $67,375,000.

c.	Total Capital/Startup and O&M Cost:

The total Capital and O&M Costs are $67,500,000.

Subpart H

a.	Total Capital/Startup Cost of Monitoring Equipment:

Only new sources will buy an organic volatile analyzer.  Estimate the
average cost of a monitor is $7,000 with a 5-year expected life. The
equipment is not capitalized, so no discount rate applies.  The average
annual cost is, therefore, $7,000/5, or $1,400/yr.  Estimate that 80
percent of facilities contract out LDAR services, and 20 percent perform
in-house.  Those facilities which contract out (4 facilities) will
purchase one unit as backup; the remaining facilities performing LDAR
in-house (1 facility) will purchase 5 units to support the program.  The
total annual capital/startup cost is, therefore, 9 units x 1400/unit, or
$12,600/yr.

b.	Total Cost of Operation and Maintenance of Monitoring Equipment:

The operation of the monitors is included in the monitoring costs. 
Maintenance costs on these units is incidental; therefore, no
maintenance or operation costs incur.

c.	Total Capital and O&M Cost for Subparts H, and I:

The total Capital and O&M Costs are $12,600.

Part 65 CAR

a.	Total Capital/Startup Cost of Monitoring Equipment:

Under the CAR, it is assumed all new sources start out under the
referencing subpart.  Therefore, there is no capital/startup cost
associated with this subpart.

b.	Total Cost of Operation and Maintenance of Monitoring Equipment:

The HON is the basis for determining O&M costs for the CAR.  The average
cost per source, based on the HON is $275,000 per year, for a total of
$22,000,000.

c.	Total Capital/Startup and O&M Cost:

The total Capital and O&M Costs are $22,000,000.

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