Burden calculations

---

Overview

# Respondents & Responses Calcs
Respondent Burden (Subs L & Y)
Agency Burden (Subs L & Y)

---

Sheet 1: # Respondents & Responses Calcs

Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports				Total Annual Responses
Year	(A) Number of New Respondents1	(B) Number of Existing Respondents2	(C) Number of Existing Respondents that keep records but do not submit reports	(D) Number of Existing Respondents That Are Also New Respondents	(E) Number of Respondents (E=A+B+C-D)		(A) Information Collection Activity	(B) Average Number of Respondents	(C) Number of Responses	(D) Number of Existing Respondents That Keep Records But Do Not Submit Reports	(E) Total Annual Responses E=(BxC)+D
Subpart L							Subpart L
1	0	17	0	0	17		Semiannual emissions report	17	2	0	34
2	0	17	0	0	17		Subtotal for subpart L				34
3	0	17	0	0	17		Subpart Y
Average	0	17	0	0	17		Annual inspection report	4	1	0	4
Subpart Y							Supplemental delay report	0.08	1	0	0.08
1	0	4	0	0	4		Subtotal for subpart Y (rounded)				4
2	0	4	0	0	4					Total	38
3	0	4	0	0	4
Average	0	4	0	0	4

---

Sheet 2: Respondent Burden (Subs L & Y)

Table 1: Annual Respondent Burden and Cost – NESHAP for Benzene Emission from Benzene Storage Vessels and Coke By-Product Recovery Plants (40 CFR Part 61, Subparts L and Y) (Renewal)
Burden Item	A	B	C	D	E	F	G	H		TECH	$106.45
	Technical person-hours per occurrence	No. of occurrences per respondent per year	Technical person-hours per respondent per year (AxB)	Respondents per year a	Technical hours per year (CxD)	Management hours per year (Ex0.05)	Clerical hours per year (Ex0.10)	Total cost per year b		MGMT	$138.43
Subpart L										CLER	$52.77
1. Applications	N/A
2. Survey and Studies	N/A									New sources	0
3. Reporting requirements										Existing sources	17
A. Familiarize with regulation requirements	1	1	1.0	17	17.0	0.85	1.70	$2,017.02
B. Required activities
Initial performance test	32	1	32	0	0	0	0	$0
Repeat performance test	32	0.2	6.4	0	0	0	0	$0
Annual maintenance inspection c	0.5	1	0.5	17	8.5	0.43	0.85	$1,009.20
C. Create information	See 3B
D. Gather existing information	See 3E
E. Write Report
Notification of construction/reconstruction	2	1	2	0	0	0	0	$0
Notification of anticipated/actual startup	2	1	2	0	0	0	0	$0
Notification of initial performance test	2	1	2	0	0	0	0	$0
Notification of physical/operational chances	8	1	8	0	0	0	0	$0
Semiannual emissions report d	12	2	24	17	408	20.4	40.8	$48,408.59
Subtotal for Reporting Requirements					499			$51,434.82
4. Recordkeeping requirements
A. Familiarize with regulation requirements	See 3A
B. Plan activities
Maintenance plan	See 3A
C. Implement activities	See 3B
File and maintain records e	33	4	132	17	2,244	112.2	224.4	$266,247.23
Performance evaluation for Method 21 f	2	2	4	17	68	3.4	6.8	$8,068.10
D. Develop record system	N/A
E. Time to enter information	N/A
F. Time to train personnel	N/A
G. Time for audits	N/A
Subtotal for Recodkeeping Requirements					2,659			$274,315.33
ANNUAL BURDEN AND COST (SUBPART L) (ROUNDED)					3,160			$326,000
Subpart Y
1. Applications	N/A									New sources	0
2. Survey and Studies	N/A									Existing sources	4
3. Reporting requirements
A. Familiarize with regulation requirements	1	1	1.0	4	4.0	0.20	0.40	$474.59
B. Required activities	N/A
C. Create information
Existing sources
Annual IFR internal inspections and EFR seal gap measurementsg	8	1	8	4	32	1.6	3.2	$3,796.75
D. Gather existing information	See 3C
E. Write Report
New sources
Notification of construction/reconstruction	See NSPS Kb
Notification of anticipated/actual startup	See NSPS Kb
Notification of performance test	N/A
Report of performance test	N/A
Notification of control installation and refill at 1st IFR degassing g,h	2	1	2	0	0	0	0	$0
Existing sources
Annual inspection reports	2	1	2	4	8	0.4	0.8	$949.19
Supplemental delay report i	2	1	2	0.08	0.16	0.01	0.02	$19.47
Quarterly emissions report j	N/A
Subtotal for Reporting Requirements					51			$5,240.00
4. Recordkeeping requirements
A. Familiarize with regulation requirements	See 3A
B. Plan activities	See 4C
C. Implement activities
File and maintain records	2	1	2	4	8	0.4	0.8	$949.19
D. Develop record system	See 4C
E. Time to enter information	See 4C
F. Time to train personnel	N/A
G. Time for audits	N/A
Subtotal for Recodkeeping Requirements					9			$949.19
ANNUAL BURDEN AND COST (SUBPART Y) (ROUNDED)					60			$6,190
TOTAL ANNUAL BURDEN AND COST (SUBPARTS L and Y) (ROUNDED)					3,220			$332,000
Capital and O&M Costs (see Section 6(b)(iii))								$0
TOTAL (ROUNDED)k					3,220			$332,000
								85	hrs/response
Assumptions:
a. We have assumed that an average of 17 respondents per year will be subject to 40 subpart L and an average of 4 respondents per year will be subject to subpart Y. No new sources will become subject to the rule over the three-year ICR period. Note that the burden for any new sources subject to subpart Y is included in the NSPS for storage vessels at 40 CFR part 60, subpart Kb.
b. This ICR uses the following labor rates: $106.45 for technical, $138.43 for managerial, and $52.77 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2015, “Table 2. Civilian Workers, by occupational and industry group.” The rates are from column 1, “Total compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry.
c. We have assumed that each respondent will take 0.5 hours to complete the annual maintenance inspection.
d. We have assumed that each respondent will take twelve hours twice per year to write semiannual emissions reports.
e. We have assumed that each respondent will take thirty-three hours four times per year to file and maintain records.											Summary of Responded Burden and Costs (Rounded)
f. We have assumed that each respondent will take two hours twice per year to complete the performance evaluation for Method 21.											Standard	Reporting (hr)	Recordkeeping (hr)	Total Burden Hours (hr)	Total Burden Costs
g. EFR - External Floating Roof. IFR - Internal Floating Roof.											Subpart L	479	2,659	3,140	$326,000
h. We believe that all vessels have been degassed and that all controls have been installed, as they were to be installed within ten years of promulgation.											Subpart Y	46	9	55	$6,190
i. We have assumed that two percent of existing sources will request a delay of repair in the annual report.											Total			3,200	$332,000
j. We have assumed that no sources will select the option for a fixed roof vented to a control device, and thus have no quarterly reports of excess emissions.
k. Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

---

Sheet 3: Agency Burden (Subs L & Y)

	Table 2: Average Annual EPA Burden and Cost – NESHAP for Benzene Emission from Benzene Storage Vessels and Coke By-Product Recovery Plants (40 CFR Part 61, Subparts L and Y) (Renewal)
	Burden Item	A	B	C	D	E	F	G	H		TECH	$47.62
		Technical person-hours per occurrence	No. of occurrences per respondent per year	Technical person-hours per respondent per year (AxB)	Respondents per year a	Technical hours per year (CxD)	Management hours per year (Ex0.05)	Clerical hours per year (Ex0.10)	Total cost per year b		MGMT	$64.16
	Subpart L										CLER	$25.76
	Initial performance test
	New plant	40	1	40	0	0	0	0	$0
	Report review
	Notification of construction	2	1	2	0	0	0	0	$0
	Notification of anticipated startup	2	1	2	0	0	0	0	$0
	Notification of actual startup	2	1	2	0	0	0	0	$0
	Notification of performance test	2	1	2	0	0	0	0	$0
	Report of performance test	8	1	8	0	0	0	0	$0
1	Review semiannual excess emissions and exemption reports c	4	2	8	17	136	6.8	13.6	$7,262.94
2	ANNUAL BURDEN AND COST (SUBPART L, ROUNDED)					156			$7,260
	Subpart Y
	Report review
	New sources
	Notification of construction/reconstruction	See NSPS Kb
	Notification of anticipated/actual startup	See NSPS Kb
	Notification of performance test	N/A
	Report of performance test	N/A
	Notification of control installation and refill at 1st IFR degassing d,e	2	1	2	0	0	0	0	$0
	Existing sources
	Annual inspection report	2	1	2	4	8	0.4	0.8	$427.23
	Supplemental delay report f	2	1	2	0.08	0.16	0.01	0.02	$8.78
	Quarterly emissions report g	N/A
	ANNUAL BURDEN AND COST (SUBPART Y) (ROUNDED)					9			$436
	TOTAL (ROUNDED)h					165			$7,700
	Assumptions:
	a. We have assumed that an average of 17 respondents per year will be subject to 40 subpart L and an average of 4 respondents per year will be subject to subpart Y. No new sources will become subject to the rule over the three-year ICR period. Note that the burden for any new sources subject to subpart Y is included in the NSPS for storage vessels at 40 CFR part 60, subpart Kb.
	b. This ICR uses the following labor rates: $47.62 for technical, $64.16 for managerial, and $25.76 for clerical labor. These rates are from the Office of Personnel Management (OPM), 2016 General Schedule, which excludes locality rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees.
	c. We have assumed it will take the Agency four hours per respondent to review excess emissions and exception reports twice per year.																Summary of Agency Burden and Costs (Rounded)
	d. IFR - Internal Floating Roof																Standard	Total Burden Hours (hr)	Total Burden Costs ($)
	e. We believe that all vessels have been degassed and that all controls have been installed, as they were to be installed within ten years of promulgation.																Subpart L	0	$0
	f. We have assumed that two percent of existing sources will request a delay of repair in the annual report.																Subpart Y	165	$7,700
	g. We have assumed that no sources will select the option for a fixed roof vented to a control device, and thus have no quarterly reports of excess emissions.																Total	165	$7,700
	h. Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
1
2