Tables

1854t10 calculations table.xlsx

The Consolidated Air Rule (CAR) for the Synthetic Organic Chemical Manufacturing Industry (SOCMI) (Renewal)

Tables

OMB: 2060-0443

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Overview

Table 1
Table 2
Table 3
Table 4
Table 5
Table 6
Table 7
Table 8
Table 9
Table F-1
Table F-2
Table F-3
Table F-4
Table F-5
Table F-6
Table F-7
Table F-8
Table F-9
Table F-10
Table F-11
Table F-12
Table G-1
Table G-2
Table G-3
Table G-4
Table G-5
Table G-6
Table G-7
Table G-8
Table G-9
Table G-10
Table G-11
Table G-12
Table G-13
Capital and O&M Costs
Number of Respondents


Sheet 1: Table 1

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

Sheet 2: Table 2

Table 2: Average Annual EPA Burden and Cost for the CAR Provisions












48.08 64.8 26.02
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Average hours per activity Number of activities per respondent per year Estimated Technical hours per plant per year
(C=AxB)
Sources per year Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) a
Report review






1. Initial notification of Part 65 applicability, Title V modification b 2 1 2 0 0 0 0
2. Review equipment leak monitoring c 5 2 10 318 3,180 159 318 $171,471.96
3. Review periodic reports d 4 1 4 80 320 16 32 $17,255.04
TOTAL ANNUAL BURDEN AND COST (rounded) e



4,030 $189,000









Assumptions:







a This ICR uses the following labor rates: $48.08 for technical, $64.80 for managerial, and $26.02 for clerical labor. These rates are from the Office of Personnel Management (OPM) 2017 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.







b Estimate all CAR sources must submit an initial notification. We estimate 1/3 of sources will submit 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.







c Estimate 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.







d Estimate 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.







e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.








Sheet 3: Table 3

Table 3: Average Annual EPA Burden and Cost for the Direct Final Standards












48.08 64.8 26.02
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Technical person-hours per occurrence No. of occurrences per respondent per year Technical person-hours per respondent per year
(C=AxB)
Respondents per year Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) a
Report review/filing 1 1 1 6 6 0.3 0.6 $323.53
TOTAL ANNUAL BURDEN AND COST (rounded) b



7 $324









Assumptions:







a This ICR uses the following labor rates: $48.08 for technical, $64.80 for managerial, and $26.02 for clerical labor. These rates are from the Office of Personnel Management (OPM) 2017 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.







b Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.








Sheet 4: Table 4

Table 4: Estimated Number of Sources Subject to Referencing Subparts that Will Opt to Comply with the CAR



Referencing subpart Estimated number of sources complying with the CAR a, 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
HON F & G - Storage Vessels 800
HON F & G - Transfer Racks 320
HON H &I -- Equipment Leaks 240
HON F & G - Process Vents 640


Assumptions:
a. This table provides estimates on a per-source basis, rather than a per-facility basis. Therefore, estimates correlate to (as described in the footnote to the appropriate Table), but do not match, facility entries in the reference subpart burden tables (Tables F-1 through F-12, and G-1 through G-13). For the purposes of this ICR, 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 and I); or
- One transfer rack (subparts BB and G).
b. From the most recently approved ICR.

Sheet 5: Table 5

Table 5: Basis for Annual Respondent Burden and Cost for the CAR


























Burden Item Annual Burden in Technical Hours
Process Vents Storage Vessels Transfer Racks Equipment Leaks Inventory Total d
With Connectors Without Connectors a
Per source b Total c Per source b Total c Per source b Total c Per source b Total c Per source b Total c Per source b Total c
1. Familiarize with regulatory requirements e 2.9 2,102.5 1.1 1,804 1.1 352 2.5 600 1 78 1.8 144 5,080.5
2. Plan activities 2.1 1,522.5 1.7 2,788 0.85 272 0.57 136.8 0.23 17.94 4.5 360 5,097.24
3. Training 1.3 942.5 0.5 820 0.5 160 0 0 0 0 0 0 1,922.5
4. Creation, testing, research and development 28 20,300 16 26,240 16 5,120 380 91,200 155 12,090 0 0 154,950
5. Gather information, monitor/ inspect 14 10,150 17 27,880 17 5,440 263 63,120 108 8,424 54 4,320 119,334
6. Process/compile and review 0 0 0 0 0 0 0 0 0 0 18 1,440 1,440
7. Complete forms 9 6,525 5.4 8,856 5.4 1,728 57 13,680 23 1,794 5.4 432 33,015
8. Record/disclose 28 20,300 2.8 4,592 2.8 896 4.7 1,128 1.9 148.2 9 720 27,784.2
9. Store/file 3 2,175 1.25 2,050 1.25 400 2.75 660 0.9 70.2 1.58 126.4 5,481.6
TOTAL 88 64,018 46 75,030 45 14,368 711 170,525 290 22,622 94 7,542 354,105














Assumptions:












a 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. Connector monitoring 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 the most recently approved CAR ICR.












c 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 estimated numbers of sources to comply with the CAR is from the most recently approved ICR and are detailed in Table 4:












- process vents - 725 725











- storage vessels - 1,640 1640











- transfer racks - 320 320











- equipment leaks with connector monitoring - 240 240











- equipment leaks without connector monitoring - 78 78











- facilities (used for inventory estimate) - 80 80











d 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 6.












e This ICR assumes all existing respondents will have to familiarize with the regulatory requirements each year.













Sheet 6: Table 6

Table 6: Annual Respondent Burden and Cost for the CAR Provisions










108.28 144.33 53.34
Burden item a (A) (B) (C) (D) (E) (F) (G)
Average hours per activity Estimated number of activities per year per respondent Technical hours per year per respondent Estimated technical hours per year Estimated managerial hours per year
(E=Dx0.5)
Estimated clerical hours per year
(F=Dx0.1)
Annual cost per year ($)
1. Familiarize with regulatory requirements b 2.76 23 63.51 5,080.5 254.03 508.05 $613,879.36
2. Plan activities 4.9 13 63.72 5,097.24 254.86 509.72 $615,902.06
3. Training 6.01 4 24.03 1,922.5 96.13 192.25 $232,296.64
4. Creation, testing, research, and development 19.56 99 1,936.88 154,950 7,747.5 15,495 $18,722,685.98
5. Gather information, monitor/inspect 2.2 677 1,491.68 119,334 5,966.7 11,933.4 $14,419,186.89
6. Process/compile and review 18 1 18 1,440 72 144 $173,995.92
7. Complete forms 82.54 5 412.69 33,015 1,650.75 3,301.5 $3,989,218.96
8. Record/disclose 13.36 26 347.30 27,784.2 1,389.21 2,778.42 $3,357,178.78
9. Store/file 1.96 35 68.52 5,481.6 274.08 548.16 $662,344.47
TOTAL ANNUAL BURDEN AND COST (rounded) c


407,000 $42,800,000
TOTAL CAPITAL AND O&M COST (rounded) c





$22,000,000
GRAND TOTAL (rounded) c





$64,800,000








Assumptions:






a 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 respondent are the total technical hours for a burden item as estimated in Table 5, 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 5.






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






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






(g) Annual Cost is the sum of costs for technical, managerial, and clerical hours. This ICR uses the following labor rates: $108.28 for technical, $144.33 for managerial, and $53.34 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2016, “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.






b This ICR assumes all existing respondents will have to familiarize with the regulatory requirements each year.






c Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.







Sheet 7: Table 7

Table 7: Annual Respondent Burden and Cost for the Direct Final Standards












108.28 144.33 53.34
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Technical person-hours per occurrence No. of occurrences per respondent per year Technical person-hours per respondent per year
(C=AxB)
Respondents per year Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) a
1. Applications N/A






2. Survey and Studies N/A






3. Acquisition, installation, and utilization of technology and systems N/A






4. Reporting requirements







A. Familiarize with regulatory requirements b 0.5 1 0.5 6 3 0.15 0.3 $362.49
B. Required activities N/A






C. Create information N/A






D. Gather existing information N/A






E. Write report b 0.5 1 0.5 6 3 0.15 0.3 $362.49
Subtotal for Reporting Requirements



7 $725
5. Recordkeeping requirements







A. Familiarize with regulatory requirements See 4A






Subtotal for Recordkeeping Requirements



0 $0
TOTAL ANNUAL BURDEN AND COST (rounded) c



7 $725
TOTAL CAPITAL AND O&M COST (rounded) c






$0
GRAND TOTAL (rounded) c






$725









Assumptions:







a This ICR uses the following labor rates: $108.28 for technical, $144.33 for managerial, and $53.34 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2016, “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.







b This ICR assumes all existing respondents will have to familiarize with the regulatory requirements each year.







c Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.








Sheet 8: Table 8

Table 8: Summary of Respondent and Agency Burden and Cost for Referencing Subparts and the CAR






















Subpart (A) (B) (C) (D) (E) (F) (G) (H) (I) (J)
Number of respondents Total annual responses a Respondent reporting burden hours a Respondent recordkeeping burden hours a Respondent burden hours a Respondent burden Costs a Agency burden hours b Agency burden costs b O&M Costs c Capital/ Startup costs c
NSPS Ka 174 194 722 45,931 46,653 $4,901,852 115 $5,392 $0 $0
NSPS Kb 802 2,465 28,888 81,254 110,142 $11,572,662 1,120 $52,531 $591,300 $27,000
NSPS VV 436 872 4,513 40,112 44,625 $4,397,778 2,006 $94,040 $0 $0
NSPS VVa 456 1004 7,671 43,298 50,968 $5,355,256 2,756 $129,208 $0 $4,200
NSPS DDD 150 324 6,169 1,627 7,796 $819,110 800 $37,530 $1,050,000 $300,000
NSPS III 17 36 219 184 403 $42,339 92 $4,292 $22,950 $13,500
NSPS NNN 2,407 5,238 33,881 26,164 60,046 $6,308,983 13,023 $610,613 $3,249,450 $2,389,500
NSPS RRR 275 598 3,856 2,989 6,845 $719,153 1,486 $69,667 $137,500 $500,000
NESHAP BB 54 216 7,662 4,844 12,506 $1,314,032 497 $23,294 $0 $0
NESHAP Y 4 8 60 9 69 $7,183 9 $431 $0 $0
NESHAP V 67 145 4,670 4,287 8,957 $941,064 335 $15,702 $0 $0
NESHAP F, G, H, and I 270 1,970 1,245,749 209,168 1,454,917 $152,868,103 5,756 $269,880 $74,250,000 $137,600
CAR d 80 400 368,965 38,256 407,221 $42,786,689 4,025 $188,727 $22,000,000 $0
CAR Revisions e 6 6 7 0 7 $725 7 $324 $0 $0 hr/response
TOTAL f 5,198 13,477 1,710,000 498,000 2,210,000 $232,000,000 32,000 $1,500,000 $101,000,000 $3,370,000 164












Assumptions:










a From Tables G-1 through G-13.










b From Tables F-1 through F-12.










c From Appendix J.










d From Tables 2 and 6.










e From Tables 3 and 7.










f Burden and cost totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.











Sheet 9: Table 9

Table 9: Summary of Total Annual Responses for Referencing Subparts and the CAR








(A) (B) (C) (D) (E)
Information Collection Activity Number of Respondents Number of Responses Number of Existing Respondents That Keep Records But Do Not Submit Reports Total Annual Responses E=(BxC)+D
NSPS Ka
Notification of construction 0 1 0 0
Notification of actual startup 0 1 0 0
Notification of gap measurement 188 1 0 188
Report of seal gap excess 6 1 0 6



Subtotal 194
NSPS Kb
Notification of construction 37 1 0 37
Notification of actual startup 37 1 0 37
Notification of IFR internal inspection 28 1 0 28
Notification of EFR gap measurement 7 1 0 7
IFR internal inspection report 28 1 0 28
EFR 1st seal gap measurement 7 1 0 7
EFR 2nd seal gap measurement 7 1 0 7
CVS operating plan report 2 1 0 2
Report of IFR failure 61 1 0 61
Notification of IFR delay of repair/emptying 6 1 0 6
EFR 1st seal gap measurement report 765 1 0 765
EFR 2nd seal gap measurement report 765 1 0 765
Notification of refill 715 1 0 715



Subtotal 2,465
NSPS VV
Notification of construction 0 1 0 0
Notification of reconstruction/modification 0 1 0 0
Notification of actual startup 0 1 0 0
Notification of initial/repeat performance test 0 1 0 0
Semiannual report 436 2 0 872



Subtotal 872
NSPS VVa
Initial performance test report 38 1 0 38
Repeat performance test report 8 1 0 8
Notification of construction 23 1 0 23
Notification of reconstruction/modification 15 1 0 15
Notification of actual startup 38 1 0 38
Notification of initial/repeat performance test 46 1 0 46
Semiannual report 418 2 0 836



Subtotal 1,004
NSPS DDD
Initial performance test report 10 1 0 10
Repeat performance test report 2 1 0 2
Notification of construction/modification 10 1 0 10
Notification of actual startup 10 1 0 10
Notification of initial/repeat performance test 12 1 0 12
Semiannual report 140 2 0 280



Subtotal 324
NSPS III
Initial performance test report 1 1 0 1
Repeat performance test report 0.2 1 0 0.2
Notification of construction/modification 1 1 0 1
Notification of actual startup 1 1 0 1
Notification of initial/repeat performance test 1.2 1 0 1.2
Semiannual report 16 2 0 32



Subtotal 36.4
NSPS NNN
Initial performance test report 177 1 0 177
Repeat performance test report 35 1 0 35
Notification of construction/modification 177 1 0 177
Notification of actual startup 177 1 0 177
Notification of initial/repeat performance test 212 1 0 212
Semiannual report 2,230 2 0 4,460



Subtotal 5,238
NSPS RRR
Initial performance test report 20 1 0 20
Repeat performance test report 4 1 0 4
Notification of construction/modification 20 1 0 20
Notification of actual startup 20 1 0 20
Notification of initial/repeat performance test 24 1 0 24
Semiannual report 255 2 0 510



Subtotal 598
NESHAP BB
Initial emission test 0 1 0 0
Monitoring performance test 0 1 0 0
Notification of construction 0 1 0 0
Notification of anticipated startup 0 1 0 0
Notification of actual startup 0 1 0 0
Notification of emission test 0 1 0 0
Report of emission test 0 1 0 0
Notification of performance test 0 1 0 0
Report of performance test 0 1 0 0
Report facilities below cut-off 0 1 0 0
Quarterly parameter excesses 54 4 0 216



Subtotal 216
NESHAP Y
Annual IFR internal inspections and EFR seal gap measurements 4 1 0 4
Notification of construction/reconstruction 0 1 0 0
Notification of anticipated startup 0 1 0 0
Notification of actual startup 0 1 0 0
Notification of emission test 0 1 0 0
Report of emission test 0 1 0 0
Notification of control installation and refill at 1st IFR degassing 0 1 0 0
Annual inspection report 4 1 0 4
Supplemental delay report 0 1 0 0
Quarterly emission report 0 4 0 0



Subtotal 8
NESHAP V
Initial performance test report 2 1 0 2
Reference method 21/22 test 2 1 0 2
Repeat performance test report 0.4 1 0 0.4
Notification of construction/reconstruction 2 1 0 2
Notification of anticipated startup 2 1 0 2
Notification of actual startup 2 1 0 2
Notification of initial/repeat performance test 2.4 1 0 2.4
Application for alternative 0.5 1 0 0.5
Initial report 2 1 0 2
Semiannual report 65 2 0 130



Subtotal 145
NESHAP F, G, H, and I
Complete reports (new respondents; see Table G-12) 5 49 0 245
Complete reports (existing respondents; see Table G-13) 345 5 0 1,725



Subtotal 1,970
CAR Provisions
Complete forms (see Table 6) 80 5 0 400



Subtotal 400
CAR Direct Final Standards
Write report (see Table 7) 6 1 0 6



Subtotal 6



Total responses (all subparts) 13,477

Sheet 10: Table F-1

Table F-1: Average Annual EPA Burden and Cost for Subpart Kaa












48.08 64.8 26.02
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) b
Report review: New plant






Vapor recovery c 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 d 0.5 1 0.5 188 94 4.7 9.4 $5,068.67
Report of gap excesses d, e 1 1 1 6 6 0.3 0.6 $323.53
TOTAL ANNUAL BURDEN AND COST (rounded) f



115 $5,390









Assumptions:







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 This ICR uses the following labor rates: $48.08 for technical, $64.80 for managerial, and $26.02 for clerical labor. These rates are from the Office of Personnel Management (OPM) 2017 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 One-time only activity required at start of construction. Any new storage vessel being constructed would be subject to NSPS Subpart Kb.







d 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 tanks using floating roof system (157) will perform a secondary seal gap measurement. Twenty percent (31) will conduct a primary seal gap measurement. Total respondents submitting a notification of either primary or secondary gap measurement: 157 + 31 = 188.







e Assume that 3 percent of respondents submitting a notification of either primary or secondary gap measurement (188) will have excessive seal gaps (primary or secondary) requiring that a single report be filed once a year. (188x3%=5.64, rounded to 6)







f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.








Sheet 11: Table F-2

Table F-2: Average Annual EPA Burden and Cost for Subpart Kb












48.08 64.8 26.02
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) b
Report review: New plant






Notification of construction 2 1 2 37 74 3.7 7.4 $3,990.23
Notification of anticipated startup 1 1 1 37 37 1.85 3.7 $1,995.11
Notification of actual startup 1 1 1 37 37 1.85 3.7 $1,995.11
Notification of initial inspection 1 1 1 37 37 1.85 3.7 $1,995.11
Report review: Existing plant






IFR failure report c 1 1 1 61 61 3.05 6.1 $3,289.24
Notification of IFR delay of repair/emptying d 1.2 1 1.2 6 7.2 0.36 0.72 $388.24
Notification of refill e 1 1 1 721 721 36.05 72.1 $38,877.76
TOTAL ANNUAL BURDEN AND COST (rounded) f



1,120 $52,500









Assumptions:







a We estimate 765 existing respondents with an average of 8,716 regulated vessels in service will be subject over the next three years. We also estimate 75 percent (6,537) of vessels have an internal floating roof (IFR), 20 percent (1,743) have an external floating roof (EFR), and 5 percent (436) have a closed vent system (CVS). For new sources, we estimate 37 respondents per year will become subject to subpart Kb, and assume a distribution similar to that of existing respondents; therefore, 28 new respondents have an IFR, 7 have an ERF, and 2 have a CVS. These estimates do not include sources subject to both subpart Kb and the HON, which we assume will comply with the HON instead.







b This ICR uses the following labor rates: $48.08 for technical, $64.80 for managerial, and $26.02 for clerical labor. These rates are from the Office of Personnel Management (OPM) 2017 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 Estimate 10 percent failure rate for the 612 respondents choosing annual visual inspections, yielding 61 reports.







d Estimate 10 percent of failed IFRs either are delayed in repair or are emptied, yielding 6 notifications.







e Assume all 6,565 IFR tanks will be serviced routinely through a shutdown, and degassed once every ten years. One tenth of these tanks will be degassed each year, for an annual average of 657 per year. This number was added to the estimated 64 visual inspection failures that would lead to internal inspections, for a total estimate of 721 notifications of refill.







f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.








Sheet 12: Table F-3

Table F-3: Average Annual EPA Burden and Cost for Subpart VV












48.08 64.8 26.02
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) b
Report review: New plant






Notification of construction 8 1 8 0 0 0 0 $0
Notification of reconstruction/ modification 2 1 2 0 0 0 0 $0
Notification of actual startup 0.5 1 0.5 0 0 0 0 $0
Notification of initial/repeat test 0.5 1 0.5 0 0 0 0 $0
Review test results 2 1 2 0 0 0 0 $0
Report review: Existing plant







Semiannual emission report 2 2 4 436 1,744 87.2 174.4 $94,039.97
TOTAL ANNUAL BURDEN AND COST (rounded) c



2,010 $94,000









Assumptions:







a All new sources are subject to subpart VVa. There are an average of 436 existing sources per year that will be subject to subpart VV over the next three years. These estimates do not include sources subject to both subpart VV and the HON, which we assume comply with the HON instead.







b This ICR uses the following labor rates: $48.08 for technical, $64.80 for managerial, and $26.02 for clerical labor. These rates are from the Office of Personnel Management (OPM) 2017 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 Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.








Sheet 13: Table F-4

Table F-4: Average Annual EPA Burden and Cost for Subpart VVa












48.08 64.8 26.02
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) b
Report review: New plant






Notification of construction c 8 1 8 23 184 9.2 18.4 $9,921.65
Notification of reconstruction/ modification c 2 1 2 15 30 1.5 3 $1,617.66
Notification of actual startup 0.5 1 0.5 38 19 0.95 1.9 $1,024.52
Notification of initial/repeat test d 0.5 1 0.5 46 23 1.15 2.3 $1,240.21
Review test results d 2 1 2 46 92 4.6 9.2 $4,960.82
Report review: Existing plant







Semiannual emission report 2.45 2 4.9 418 2,048.2 102.41 204.82 $110,443.04
TOTAL ANNUAL BURDEN AND COST (rounded) e



2,760 $129,000









Assumptions:







a Assume there will be an average of 38 new, modified, or reconstructed facilities each year and an average of 418 existing facilities over the next 3 years. 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 This ICR uses the following labor rates: $48.08 for technical, $64.80 for managerial, and $26.02 for clerical labor. These rates are from the Office of Personnel Management (OPM) 2017 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 Estimate 23 sources will be new due to construction while 15 will be due to reconstruction or modification.







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







e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.








Sheet 14: Table F-5

Table F-5: Average Annual EPA Burden and Cost for Subpart DDD












48.08 64.8 26.02
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) b
Report review: New plant






Notification of construction/ modification 2 1 2 10 20 1 2 $1,078.44
Notification of actual startup 2 1 2 10 20 1 2 $1,078.44
Initial performance test 8 1 8 10 80 4 8 $4,313.76
Repeat performance test c 8 1 8 2 16 0.8 1.6 $862.75
Report review: Existing plant







Semiannual report 2 2 4 140 560 28 56 $30,196.32
TOTAL ANNUAL BURDEN AND COST (rounded) d



800 $37,500









Assumptions:







a Assume 10 new affected sources per year and an average of 140 existing affected sources over the next three years.







b This ICR uses the following labor rates: $48.08 for technical, $64.80 for managerial, and $26.02 for clerical labor. These rates are from the Office of Personnel Management (OPM) 2017 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 Assume 20 percent of initial performance tests must be repeated due to failure.







d Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.








Sheet 15: Table F-6

Table F-6: Average Annual EPA Burden and Cost for Subpart III












48.08 64.8 26.02
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) b
Report review: New plant






Notification of construction/ modification 2 1 2 1 2 0.1 0.2 $107.84
Notification of anticipated startup 2 1 2 1 2 0.1 0.2 $107.84
Notification of actual startup 2 1 2 1 2 0.1 0.2 $107.84
Initial performance test 8 1 8 1 8 0.4 0.8 $431.38
Repeat performance test c 8 1 8 0.2 1.6 0.08 0.16 $86.28
Report review: Existing plant







Semiannual report 2 2 4 16 64 3.2 6.4 $3,451.01
TOTAL ANNUAL BURDEN AND COST (rounded) d



92 $4,290









Assumptions:







a Assume 1 new affected source per year and an average of 16 existing affected sources over the 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.







b This ICR uses the following labor rates: $48.08 for technical, $64.80 for managerial, and $26.02 for clerical labor. These rates are from the Office of Personnel Management (OPM) 2017 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 Assume 20 percent of initial performance tests must be repeated due to failure.







d Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.








Sheet 16: Table F-7

Table F-7: Average Annual EPA Burden and Cost for Subpart NNN












48.08 64.8 26.02
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) b
Report review: New plant






Notification of construction/ modification 2 1 2 177 354 17.7 35.4 $19,088.39
Notification of actual startup 2 1 2 177 354 17.7 35.4 $19,088.39
Initial performance test 8 1 8 177 1,416 70.8 141.6 $76,353.55
Repeat performance test c 8 1 8 35 280 14 28 $15,098.16
Report review: Existing plant







Semiannual report 2 2 4 2,230 8,920 446 892 $480,984.24
TOTAL ANNUAL BURDEN AND COST (rounded) d



13,000 $611,000









Assumptions:







a Assume 177 new affected sources per year subject to subpart NNN and not the HON, and 2,23 existing affected sources over the next three years. These estimates do not include sources subject to both Subpart NNN and the HON, which are assumed to be complying with the HON.







b This ICR uses the following labor rates: $48.08 for technical, $64.80 for managerial, and $26.02 for clerical labor. These rates are from the Office of Personnel Management (OPM) 2017 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 Assume 20 percent of initial performance tests must be repeated due to failure.







d Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.








Sheet 17: Table F-8

Table F-8: Average Annual EPA Burden and Cost for Subpart RRR












48.08 64.8 26.02
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) b
Report review: New plant






Notification of construction/ modification 2 1 2 20 40 2 4 $2,156.88
Notification of actual startup 2 1 2 20 40 2 4 $2,156.88
Initial performance test 8 1 8 20 160 8 16 $8,627.52
Repeat performance test c 8 1 8 4 32 1.6 3.2 $1,725.50
Report review: Existing plant







Semiannual report 2 2 4 255 1,020 51 102 $55,000.44
TOTAL ANNUAL BURDEN AND COST (rounded) d



1,490 $69,700









Assumptions:







a Assume 20 new affected sources per year subject to subpart RRR and not the HON, and 255 existing affected sources over the next three years. These estimates do not include sources subject to both Subpart RRR and the HON, which are assumed to be complying with the HON.







b This ICR uses the following labor rates: $48.08 for technical, $64.80 for managerial, and $26.02 for clerical labor. These rates are from the Office of Personnel Management (OPM) 2017 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 Assume 20 percent of initial performance tests must be repeated due to failure.







d Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.








Sheet 18: Table F-9

Table F-9: Average Annual EPA Burden and Cost for Subpart BB












48.08 64.8 26.02
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) b
Report review: New plant






Notification of construction 0.5 1 0.5 0 0 0 0 $0
Notification of anticipated startup 0.5 1 0.5 0 0 0 0 $0
Notification of actual startup 0.5 1 0.5 0 0 0 0 $0
Initial report 8 1 8 0 0 0 0 $0
Notification of emission test 0.5 1 0.5 0 0 0 0 $0
Report of emission test 4 1 4 0 0 0 0 $0
Notification of performance test 0.5 1 0.5 0 0 0 0 $0
Report of performance test 8 1 8 0 0 0 0 $0
Review test results 8 1 8 0 0 0 0 $0
Report review: Existing plant







Quarterly report 2 4 8 54 432 21.6 43.2 $23,294.30
TOTAL ANNUAL BURDEN AND COST (rounded) c



497 $23,300









Assumptions:







a We estimate an average of 54 existing facilities will be subject to the standard, and that no new sources will become subject over the next three years. We estimate 3 tank truck/railcars and 131 marine vessels are subject to the standards. We assume 50 percent of marine vessels (66) operate at negative pressure and do not conduct annual vapor-tightness tests. We also assume all other transfer racks subject to Subpart BB are complying with the HON.







b This ICR uses the following labor rates: $48.08 for technical, $64.80 for managerial, and $26.02 for clerical labor. These rates are from the Office of Personnel Management (OPM) 2017 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 Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.








Sheet 19: Table F-10

Table F-10: Average Annual EPA Burden and Cost for Subpart Y












48.08 64.8 26.02
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) b
Report review: New plant






Notification of construction See NSPS Kb






Notification of anticipated startup See NSPS Kb






Notification of 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 c 1 1 1 0 0 0 0 $0
Report review: Existing plant







Annual IFR internal inspection and EFR seal gap measurement 2 1 2 4 8 0.4 0.8 $431.38
Supplemental delay report d 1 1 1 0 0 0 0 $0
Quarterly emission report e N/A






TOTAL ANNUAL BURDEN AND COST (rounded) f



9 $431









Assumptions:







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







b This ICR uses the following labor rates: $48.08 for technical, $64.80 for managerial, and $26.02 for clerical labor. These rates are from the Office of Personnel Management (OPM) 2017 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 believe that all vessels have been degassed and that all controls have been installed, as they were to be installed within 10 years of promulgation.







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







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







f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.








Sheet 20: Table F-11

Table F-11: Average Annual EPA Burden and Cost for Subpart V












48.08 64.8 26.02
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) b
Report review: New plant






Notification of construction 2 1 2 2 4 0.2 0.4 $215.69
Notification of anticipated startup 2 1 2 2 4 0.2 0.4 $215.69
Notification of actual startup 2 1 2 2 4 0.2 0.4 $215.69
Initial performance test 8 1 8 2 16 0.8 1.6 $862.75
Repeat performance test c 8 1 8 0.4 3.2 0.16 0.32 $172.55
Semiannual report 2 2 4 65 260 13 26 $14,019.72
TOTAL ANNUAL BURDEN AND COST (rounded) d



335 $15,700









Assumptions:







a Assume 2 new sources per year and 65 existing sources subject to Subpart V, but not the HON.







b This ICR uses the following labor rates: $48.08 for technical, $64.80 for managerial, and $26.02 for clerical labor. These rates are from the Office of Personnel Management (OPM) 2017 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 Assume 20 percent of initial performance tests must be repeated due to failure.







d Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.








Sheet 21: Table F-12

Table F-12: Average Annual EPA Burden and Cost for Sources Subject to the HON








48.08 64.8 26.02
Burden item (A) (B) (C) (D) (E) (F)
Average hours per activity Number of activities per year Technical hours per year
(C=AxB)
Management hours per year
(D=Cx0.05)
Clerical hours per year
(E=Cx0.1)
Total cost per year ($)
Report review:




1. Initial 2 5 10 0.5 1 $539.22
2. Implementation plan or permit 20 5 100 5 10 $5,392.20
3. Compliance status 40 5 200 10 20 $10,784.40
4. Review equipment leak monitoring 7 265 1,855 92.75 185.5 $100,025.31
5. Notification of construction/reconstruction 2 5 10 0.5 1 $539.22
6. Notification of anticipated startup 2 5 10 0.5 1 $539.22
7. Notification of actual startup 2 5 10 0.5 1 $539.22
8. Notification of performance test 2 5 10 0.5 1 $539.22
9. Review of test results 8 5 40 2 4 $2,156.88
10. Review periodic reports 4 690 2,760 138 276 $148,824.72
TOTAL ANNUAL BURDEN AND COST (rounded)

5,760 $270,000







See Attachment H for assumptions and further description of activities.






Sheet 22: Table G-1

Table G-1: Annual Respondent Burden and Cost for Subpart Ka a












108.28 144.33 53.34
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) b
1. Applications N/A






2. Survey and Studies N/A






3. Reporting requirements







A. Familiarize with regulatory requirements c 1 1 1 174 174 8.7 17.4 $21,024.51
B. Required activities







Vapor recovery information 20 1 20 0 0 0 0 $0
Measure seal gap See 4E






C. Create information See 3B






D. Gather existing information d 1 1 1 157 157 7.85 15.7 $18,970.39
E. Write report







Notification of construction 2 1 2 0 0 0 0 $0
Notification of actual startup 2 1 2 0 0 0 0 $0
Notification of gap measurement d 1.5 1 1.5 188 282 14.1 28.2 $34,074.20
Report of seal gap excess e 2.5 1 2.5 6 15 0.75 1.5 $1,812.46
Information on vapor recovery See 3B






Subtotal for Reporting Requirements



722 $75,882
4. Recordkeeping requirements







A. Familiarize with regulatory requirements See 3A






B. Plan activities See 3B






C. Implement activities See 3B






D. Develop record system N/A






E. Time to enter information







New tank seal gap measurements 5 50 250 0 0 0 0 $0
Secondary seal gap measurements d, e, f 5 50 250 157 39,250 1,962.5 3,925 $4,742,597.13
Primary seal gap measurements d, e, g 2 10 20 31 620 31 62 $74,914.91
Fill/refill record h, i 0.2 10 2 35 70 3.5 7 $8,458.14
Subtotal for Recordkeeping Requirements



45,931 $4,825,970
TOTAL ANNUAL BURDEN AND COST (rounded) j



46,700 $4,900,000
TOTAL CAPITAL AND O&M COST (rounded) j






$0
GRAND TOTAL (rounded) j






$4,900,000









Assumptions:







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 This ICR uses the following labor rates: $108.28 for technical, $144.33 for managerial, and $53.34 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2016, “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 This ICR assumes all existing respondents will have to familiarize with the regulatory requirements each year.







d 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 tanks using floating roof system (157) will perform a secondary seal gap measurement. Twenty percent (31) will conduct a primary seal gap measurement. Total respondents submitting a notification of either primary or secondary gap measurement: 157 + 31 = 188.







e Assume that 3 percent of respondents submitting a notification of either primary or secondary gap measurement (188) will have excessive seal gaps (primary or secondary) requiring that a single report be filed once a year.







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







g Estimate two hours to conduct primary seal measurements every five years for the average 50 tanks per respondent (10 tanks per respondent per year).







h During any one year, a respondent would change liquid at approximately 20 percent of all facilities (35).







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







j Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.








Sheet 23: Table G-2

Table G-2: Annual Respondent Burden and Cost for Subpart Kb












108.28 144.33 53.34
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) b
1. Applications N/A






2. Survey and Studies N/A






3. Reporting requirements







A. Familiarize with regulatory requirements c 1 1 1 802 802 40.1 80.2 $96,906.06
B. Required activities







One-time-only requirements







Notification of construction 2 1 2 37 74 3.7 7.4 $8,941.46
Notification of actual startup 2 1 2 37 74 3.7 7.4 $8,941.46
Notification of physical/ operational changes d N/A






Notification of malfunction d N/A






Notification of initial inspection







IFR internal inspection 2 1 2 28 56 2.8 5.6 $6,766.51
EFR gap measurement 2 1 2 7 14 0.7 1.4 $1,691.63
Initial inspection report







IFR internal inspection report 12 1 12 28 336 16.8 33.6 $40,599.05
EFR 1st seal gap measurement 12 1 12 7 84 4.2 8.4 $10,149.76
EFR 2nd seal gap measurement 8 1 8 7 56 2.8 5.6 $6,766.51
CVS operating plan report 8 1 8 2 16 0.8 1.6 $1,933.29
Repeat requirements







Internal IFR inspection e 12 1 12 153 1,836 91.8 183.6 $221,844.80
Visual IFR inspection e 8 1 8 612 4,896 244.8 489.6 $591,586.13
Report of IFR failure e, f 2 1 2 61 122 6.1 12.2 $14,741.32
Notification of IFR delay of repair/emptying e, f, g 4 1 4 6 24 1.2 2.4 $2,899.93
EFR 1st seal gap measurement report 12 1 12 765 9,180 459 918 $1,109,223.99
EFR 2nd seal gap measurement report 8 1 8 765 6,120 306 612 $739,482.66
Notification of refill h 2 1 2 715 1,430 71.5 143 $172,787.62
Subtotal for Reporting Requirements



28,888 $3,035,262
4. Recordkeeping requirements







A. Familiarize with regulatory requirements c 1 1 1 802 802 40.1 80.2 $96,906.06
B. Gather and record information







Vessel volumes, liquid vapor pressures, flares 8 1 8 765 6,120 306 612 $739,482.66
113b(a) inspection 12 1 12 765 9,180 459 918 $1,109,223.99
113b(b) gap measurement 12 1 12 765 9,180 459 918 $1,109,223.99
C. Develop record system 10 1 10 3 30 1.5 3 $3,624.92
D. Time to enter information







CVS parameter records 2 52 104 436 45,344 2,267.2 4,534.4 $5,478,938.19
E. Train personnel N/A






F. Audits N/A






Subtotal for Recordkeeping Requirements



81,254 $8,537,400
TOTAL ANNUAL BURDEN AND COST (rounded) i



110,000 $11,600,000
TOTAL CAPITAL AND O&M COST (rounded) i






$618,000
GRAND TOTAL (rounded) i






$12,200,000









Assumptions:







a We estimate 802 existing respondents with an average of 8,753 regulated vessels in service will be subject over the next three years. We also estimate 75 percent (6,565) of vessels have an internal floating roof (IFR), 20 percent (1,751) have an external floating roof (EFR), and 5 percent (438) have a closed vent system (CVS). For new sources, we estimate 37 sources per year will become subject to subpart Kb, and assume a distribution similar to that of existing respondents; therefore, 28 new respondents have an IFR, 7 have an ERF, and 2 have a CVS. These estimates do not include sources subject to both subpart Kb and the HON, which we assume comply with the HON instead.







b This ICR uses the following labor rates: $108.28 for technical, $144.33 for managerial, and $53.34 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2016, “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 This ICR assumes all existing respondents will have to familiarize with the regulatory requirements each year.







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







e For each of the 6,537 IFRs associated with the 765 existing respondents, 80 percent (612) will conduct an annual visual inspection, while 20 percent (153) will conduct an internal inspection. These activities are required to generate the information for the IFR failure report and EFR primary and secondary seal gap reports, but do not require response.







f Estimate 10 percent failure rate for the 612 respondents choosing annual visual inspections, yielding 61 reports.







g Estimate 10 percent of failed IFRs either are delayed in repair or are emptied, yielding 6 notifications.







h Assume all 6,537 IFR tanks will be serviced routinely through a shutdown, and degassed once every ten years. One tenth of these tanks will be degassed each year, for an annual average of 654 per year. This number was added to the estimated 61 visual inspection failures that would lead to internal inspections, for a total estimate of 715 notifications of refill.







i Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.








Sheet 24: Table G-3

Table G-3: Annual Respondent Burden and Cost for Subpart VV












108.28 144.33 53.34
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) b
1. Applications N/A






2. Survey and Studies N/A






3. Reporting requirements







A. Familiarize with regulatory requirements c 1 1 1 436 436 21.8 43.6 $52,682.10
B. Required activities







Initial performance test report 48 1 48 0 0 0 0 $0
Repeat performance test report d 48 1 48 0 0 0 0 $0
C. Create information See 3B






D. Gather existing information See 3E






E. Write report







Notification of construction 2 1 2 0 0 0 0 $0
Notification of reconstruction/modification 2 1 2 0 0 0 0 $0
Notification of actual startup 2 1 2 0 0 0 0 $0
Notification of initial/repeat performance test 2 1 2 0 0 0 0 $0
Semiannual report 4 2 8 436 3,488 174.4 348.8 $421,456.78
Subtotal for Reporting Requirements



4,513 $474,139
4. Recordkeeping requirements







A. Familiarize with regulatory requirements 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 operating parameters 80 1 80 436 34,880 1,744 3,488 $3,923,638.99
F. Train personnel N/A






G. Audits N/A






Subtotal for Recordkeeping Requirements



40,112 $3,923,639
TOTAL ANNUAL BURDEN AND COST (rounded) e



44,600 $4,400,000
TOTAL CAPITAL AND O&M COST (rounded) e






$0
GRAND TOTAL (rounded) e






$4,400,000









Assumptions:







a All new sources are subject to Subpart VVa. There is an average of 436 existing sources per year that will be subject to subpart VV over the next three years. These estimates do not include sources subject to both subpart VV and the HON, which we assume comply with the HON instead.







b This ICR uses the following labor rates: $108.28 for technical, $144.33 for managerial, and $53.34 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2016, “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 This ICR assumes all existing respondents will have to familiarize with the regulatory requirements each year.







d Assume 20 percent of performance tests must be repeated.







e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.








Sheet 25: Table G-4

Table G-4: Annual Respondent Burden and Cost for Subpart VVa












108.28 144.33 53.34
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) b
1. Applications N/A






2. Survey and Studies N/A






3. Reporting requirements







A. Familiarize with regulatory requirements c 1 1 1 456 456 22.8 45.6 $55,098.71
B. Required activities







Initial performance test report 48 1 48 38 1,824 91.2 182.4 $220,394.83
Repeat performance test report d 48 1 48 8 384 19.2 38.4 $46,398.91
C. Create information See 3B






D. Gather existing information See 3E






E. Write report







Notification of construction e 2 1 2 23 46 2.3 4.6 $5,558.20
Notification of reconstruction/modification e 2 1 2 15 30 1.5 3 $3,624.92
Notification of actual startup 2 1 2 38 76 3.8 7.6 $9,183.12
Notification of initial/repeat performance test d 2 1 2 46 92 4.6 9.2 $11,116.41
Semiannual report 4.5 2 9 418 3,762 188.1 376.2 $454,564.34
Subpart for Reporting Requirements



7,671 $805,939
4. Recordkeeping requirements







A. Familiarize with regulatory requirements 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 operating parameters - average facilities f 89.5 1 89.5 376 33,652 1,682.6 3,365.2 $4,066,187.99
Records of operating parameters - small facilities f 95.2 1 95.2 42 3,998.4 199.92 399.84 $483,128.67
F. Train personnel N/A






G. Audits N/A






Subtotal for Recordkeeping Requirements



43,298 $4,549,317
TOTAL ANNUAL BURDEN AND COST (rounded) g



51,000 $5,360,000
TOTAL CAPITAL AND O&M COST (rounded) g






$4,200
GRAND TOTAL (rounded) g






$5,360,000









Assumptions:







a Assume there will be an average of 38 new, modified, or reconstructed facilities each year and an average of 418 existing facilities over the next 3 years. 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 This ICR uses the following labor rates: $108.28 for technical, $144.33 for managerial, and $53.34 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2016, “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 This ICR assumes all existing respondents will have to familiarize with the regulatory requirements each year.







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







e Estimate 23 sources will be new due to construction while 15 will be due to reconstruction or modification.







f Assume 10 percent are small facilities that will record instrument readings manually while the other 90 percent use automated equipment to capture instrument readings electronically.







g Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.








Sheet 26: Table G-5

Table G-5: Annual Respondent Burden and Cost for Subpart DDD












108.28 144.33 53.34
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) b
1. Applications N/A






2. Survey and Studies N/A






3. Reporting requirements







A. Familiarize with regulatory requirements c 1 1 1 150 150 7.5 15 $18,124.58
B. Required activities







Initial performance test report 360 1 360 10 3,600 180 360 $434,989.80
Repeat performance test report d 360 1 360 2 720 36 72 $86,997.96
C. Write report







Notification of construction/modification 2 1 2 10 20 1 2 $2,416.61
Notification of actual startup 1 1 1 10 10 0.5 1 $1,208.31
Notification of initial/repeat performance test 2 1 2 12 24 1.2 2.4 $2,899.93
Semiannual report 3 2 6 140 840 42 84 $101,497.62
Subtotal for Reporting Requirements



6,169 $648,135
4. Recordkeeping requirements







Records of operating parameters for control devices 1 12 12 10 120 6 12 $14,499.66
Records of operating conditions exceeding last performance test 1 8 8 140 1,120 56 112 $135,330.16
Records of startup, shutdown, malfunction, etc. 0.25 5 1.25 140 175 8.75 17.5 $21,145.34
Subtotal for Recordkeeping Requirements



1,627 $170,975
TOTAL ANNUAL BURDEN AND COST (rounded) e



7,800 $819,000
TOTAL CAPITAL AND O&M COST (rounded) e






$1,350,000
GRAND TOTAL (rounded) e






$2,170,000









Assumptions:







a Assume 10 new affected sources per year and an average of 140 existing affected sources over the next three years.







b This ICR uses the following labor rates: $108.28 for technical, $144.33 for managerial, and $53.34 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2016, “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 This ICR assumes all existing respondents will have to familiarize with the regulatory requirements each year.







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







e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.








Sheet 27: Table G-6

Table G-6: Annual Respondent Burden and Cost for Subpart III












108.28 144.33 53.34
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) b
1. Applications N/A






2. Survey and Studies N/A






3. Reporting requirements







A. Familiarize with regulatory requirements c 1 1 1 17 17 0.85 1.7 $2,054.12
B. Required activities







Initial performance test report 60 1 60 1 60 3 6 $7,249.83
Repeat performance test report d 60 1 60 0.2 12 0.6 1.2 $1,449.97
C. Write report







Notification of construction/modification 2 1 2 1 2 0.1 0.2 $241.66
Notification of actual startup 1 1 1 1 1 0.05 0.1 $120.83
Notification of initial/repeat performance test 2 1 2 1.2 2.4 0.12 0.24 $289.99
Semiannual report 3 2 6 16 96 4.8 9.6 $11,599.73
Subtotal for Reporting Requirements



219 $23,006
4. Recordkeeping requirements







Records of operating parameters for control devices 1 12 12 1 12 0.6 1.2 $1,449.97
Records of operating conditions exceeding last performance test 1 8 8 16 128 6.4 12.8 $15,466.30
Records of startup, shutdown, malfunction, etc. 0.25 5 1.25 16 20 1 2 $2,416.61
Subtotal for Recordkeeping Requirements



184 $19,333
TOTAL ANNUAL BURDEN AND COST (rounded) e



403 $42,300
TOTAL CAPITAL AND O&M COST (rounded) e






$36,500
GRAND TOTAL (rounded) e






$78,800









Assumptions:







a Assume 1 new affected source per year and an average of 16 existing affected sources over the 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.







b This ICR uses the following labor rates: $108.28 for technical, $144.33 for managerial, and $53.34 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2016, “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 This ICR assumes all existing respondents will have to familiarize with the regulatory requirements each year.







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







e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.








Sheet 28: Table G-7

Table G-7: Annual Respondent Burden and Cost for Subpart NNN












108.28 144.33 53.34
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) b
1. Applications N/A






2. Survey and Studies N/A






3. Reporting requirements







A. Familiarize with regulatory requirements c 1 1 1 2,407 2,407 120.35 240.7 $290,839.01
B. Required activities







Initial performance test report 60 1 60 177 10,620 531 1,062 $1,283,219.91
Repeat performance test report d 60 1 60 35 2,100 105 210 $253,744.05
C. Write report







Notification of construction/modification 2 1 2 177 354 17.7 35.4 $42,774.00
Notification of actual startup 1 1 1 177 177 8.85 17.7 $21,387.00
Notification of initial/repeat performance test 2 1 2 212 424 21.2 42.4 $51,232.13
Semiannual report 3 2 6 2,230 13,380 669 1,338 $1,616,712.09
Subtotal for Reporting Requirements



33,881 $3,559,908
4. Recordkeeping requirements







Records of operating parameters for control devices 1 12 12 177 2,124 106.2 212.4 $256,643.98
Records of operating conditions exceeding last performance test 1 8 8 2,230 17,840 892 1,784 $2,155,616.12
Records of startup, shutdown, malfunction, etc. 0.25 5 1.25 2,230 2,787.5 139.38 278.75 $336,815.02
Subtotal for Recordkeeping Requirements



26,164 $2,749,075
TOTAL ANNUAL BURDEN AND COST (rounded) e



60,000 $6,310,000
TOTAL CAPITAL AND O&M COST (rounded) e






$5,640,000
GRAND TOTAL (rounded) e






$12,000,000









Assumptions:







a Assume 177 new affected sources per year subject to subpart NNN and not the HON, and 2,230 existing affected sources over the next three years. These estimates do not include sources subject to both Subpart NNN and the HON, which are assumed to be complying with the HON.







b This ICR uses the following labor rates: $108.28 for technical, $144.33 for managerial, and $53.34 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2016, “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 This ICR assumes all existing respondents will have to familiarize with the regulatory requirements each year.







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







e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.








Sheet 29: Table G-8

Table G-8: Annual Respondent Burden and Cost for Subpart RRR












108.28 144.33 53.34
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) b
1. Applications N/A






2. Survey and Studies N/A






3. Reporting requirements







A. Familiarize with regulatory requirements c 1 1 1 275 275 13.75 27.5 $33,228.39
B. Required activities







Initial performance test report 60 1 60 20 1,200 60 120 $144,996.60
Repeat performance test report d 60 1 60 4 240 12 24 $28,999.32
C. Write report







Notification of construction/modification 2 1 2 20 40 2 4 $4,833.22
Notification of actual startup 1 1 1 20 20 1 2 $2,416.61
Notification of initial/repeat performance test 2 1 2 24 48 2.4 4.8 $5,799.86
Semiannual report 3 2 6 255 1,530 76.5 153 $184,870.67
Subtotal for Reporting Requirements



3,856 $405,145
4. Recordkeeping requirements







Records of operating parameters for control devices 1 12 12 20 240 12 24 $28,999.32
Records of operating conditions exceeding last performance test 1 8 8 255 2,040 102 204 $246,494.22
Records of startup, shutdown, malfunction, etc. 0.25 5 1.25 255 318.75 15.94 31.88 $38,514.72
Subtotal for Recordkeeping Requirements



2,989 $314,008
TOTAL ANNUAL BURDEN AND COST (rounded) e



6,840 $719,000
TOTAL CAPITAL AND O&M COST (rounded) e






$638,000
GRAND TOTAL (rounded) e






$1,360,000









Assumptions:







a Assume 20 new affected sources per year subject to subpart RRR and not the HON, and 255 existing affected sources over the next three years. These estimates do not include sources subject to both Subpart RRR and the HON, which are assumed to be complying with the HON.







b This ICR uses the following labor rates: $108.28 for technical, $144.33 for managerial, and $53.34 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2016, “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 This ICR assumes all existing respondents will have to familiarize with the regulatory requirements each year.







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







e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.








Sheet 30: Table G-9

Table G-9: Annual Respondent Burden and Cost for Subpart BB












108.28 144.33 53.34
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) b
1. Applications N/A






2. Survey and Studies N/A






3. Reporting requirements







A. Familiarize with regulatory requirements c 1 1 1 54 54 2.7 5.4 $6,525
B. Required activities







Initial emission test 20 1 20 0 0 0 0 $0
Monitoring performance test 280 1 280 0 0 0 0 $0
Vapor-tightness test tank truck and railcars 11 1 11 3 33 1.65 3.3 $3,987.41
Marine vessels 80 1 80 66 5,280 264 528 $637,985.04
Closed vent leak inspection 8 1 8 54 432 21.6 43.2 $52,198.78
C. Create information See 3B






D. Gather existing information See 3E






E. Write report







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 emission test 2 1 2 0 0 0 0 $0
Report of emission test 8 1 8 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
Report facilities below cut-off d 8 1 8 0 0 0 0 $0
Quarterly parameter excesses 4 4 16 54 864 43.2 86.4 $104,397.55
Subtotal for Reporting Requirements



7,662 $805,094
4. Recordkeeping requirements







A. Familiarize with regulatory requirements See 3A






B. Plan activities See 4C






C. Implement activities See 3B






D. Develop record system N/A






E. Time to enter information







Facilities above cut-off 1.5 52 78 54 4,212 210.6 421.2 $508,938.07
Facilities below cut-off d 0.5 52 26 0 0 0 0 $0
F. Train personnel N/A






Subtotal for Recordkeeping Requirements



4,844 $508,938
TOTAL ANNUAL BURDEN AND COST (rounded) e



12,500 $1,310,000
TOTAL CAPITAL AND O&M COST (rounded) e






$0
GRAND TOTAL (rounded) e






$1,310,000









Assumptions:







a We estimate an average of 54 existing facilities will be subject to the standard, and that no new sources will become subject over the next three years. We estimate 3 tank truck/railcars and 131 marine vessels are subject to the standards. We assume 50 percent of marine vessels (66) operate at negative pressure and do not conduct annual vapor-tightness tests. We also assume all other transfer racks subject to subpart BB are complying with the HON.







b This ICR uses the following labor rates: $108.28 for technical, $144.33 for managerial, and $53.34 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2016, “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 This ICR assumes all existing respondents will have to familiarize with the regulatory requirements each year.







d For sources below the low quantity applicability for control requirements, a report is only required the first year of operation. We assume existing sources previously have submitted this report.







e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.








Sheet 31: Table G-10

Table G-10: Annual Respondent Burden and Cost for Subpart Y












108.28 144.33 53.34
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) b
1. Applications N/A






2. Survey and Studies N/A






3. Reporting requirements







A. Familiarize with regulatory requirements c 1 1 1 4 4 0.2 0.4 483.322
B. Required activities







Initial performance test N/A






C. Create information







Annual IFR internal inspections and EFR seal gap measurements 8 1 8 4 32 1.6 3.2 $3,866.58
D. Gather existing information See 3C






E. Write report







Notification of construction/ reconstruction See NSPS Kb






Notification of anticipated startup See NSPS Kb






Notification of actual startup See NSPS Kb






Notification of emission test N/A






Report of emission test N/A






Notification of control installation and refill at 1st IFR degassing d 2 1 2 0 0 0 0 $0
Annual inspection report 2 2 4 4 16 0.8 1.6 $1,933.29
Supplemental delay report e 2 1 2 0 0 0 0 $0
Quarterly emission report f None expected






Subtotal for Reporting Requirements



60 $6,283
4. Recordkeeping requirements







A. Familiarize with regulatory requirements See 3A






B. Plan activities See 4C






C. Implement activities







Filing and maintaining records 2 1 2 4 8 0.4 0.8 $966.64
D. Develop record system See 4C






E. Time to enter information See 4C






F. Train personnel N/A






G. Audits N/A






Subtotal for Recordkeeping Requirements



9 $900
TOTAL ANNUAL BURDEN AND COST (rounded) g



69 $7,180
TOTAL CAPITAL AND O&M COST (rounded) g






$0
GRAND TOTAL (rounded) g






$7,180









Assumptions:







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







b This ICR uses the following labor rates: $108.28 for technical, $144.33 for managerial, and $53.34 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2016, “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 This ICR assumes all existing respondents will have to familiarize with the regulatory requirements each year.







d We believe that all vessels have been degassed and that all controls have been installed, as they were to be installed within 10 years of promulgation.







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







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







g Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.








Sheet 32: Table G-11

Table G-11: Annual Respondent Burden and Cost for Subpart V












108.28 144.33 53.34
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) b
1. Applications N/A






2. Survey and Studies N/A






3. Reporting requirements







A. Familiarize with regulatory requirements c 1 1 1 67 67 3.35 6.7 $8,095.64
B. Required activities







Initial performance test 20 1 20 2 40 2 4 $4,833.22
Reference method 21/22 test 4 1 4 2 8 0.4 0.8 $966.64
Repeat performance test d 20 1 20 0.4 8 0.4 0.8 $966.64
C. Create information See 3B






D. Gather existing information See 3B






E. Write report







Notification of construction/reconstruction 2 1 2 2 4 0.2 0.4 $483.32
Notification of anticipated startup 2 1 2 2 4 0.2 0.4 $483.32
Notification of actual startup 2 1 2 2 4 0.2 0.4 $483.32
Notification of initial/repeat performance test d 2 1 2 2.4 4.8 0.24 0.48 $579.99
Report of performance test See 3B






Application for alternative 10 1 10 0.5 5 0.25 0.5 $604.15
Initial report 8 1 8 2 16 0.8 1.6 $1,933.29
Semiannual report 30 2 60 65 3,900 195 390 $471,238.95
Subtotal for Reporting Requirements



4,670 $490,668
4. Recordkeeping requirements







A. Familiarize with regulatory requirements See 3A






B. Plan activities See 4C






C. Implement activities See 3B






D. Develop record system N/A






E. Time to enter information







Record of startup, shutdown, malfunction, etc. 1.5 1 1.5 2 3 0.15 0.3 $362.49
Record of operation, parameters, and emissions 0.1 365 36.5 65 2,372.5 118.63 237.25 $286,670.36
Record of leaks detected 0.4 52 20.8 65 1,352 67.6 135.2 $163,362.84
F. Train personnel N/A






G. Audits N/A






Subtotal for Recordkeeping Requirements



4,287 $450,396
TOTAL ANNUAL BURDEN AND COST (rounded) e



8,960 $941,000
TOTAL CAPITAL AND O&M COST (rounded) e






$0
GRAND TOTAL (rounded) e






$941,000









Assumptions:







a Assume 2 new sources per year and 65 existing sources subject to subpart V, but not the HON.







b This ICR uses the following labor rates: $108.28 for technical, $144.33 for managerial, and $53.34 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2016, “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 This ICR assumes all existing respondents will have to familiarize with the regulatory requirements each year.







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







e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.








Sheet 33: Table G-12

Table G-12: Annual Respondent Burden and Cost for New Sources Subject to the HON












108.28 144.33 53.34
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Average hours per activity Number of activities per year per respondent Technical hours per year per respondent Estimated number of New Respondents Estimated technical hours per year
(E=CxD)
Estimated managerial hours per year
(F=Ex0.05)
Estimated clerical hours per year
(G=Ex0.1)
Total cost per year ($) b
1. Familiarize with regulatory requirements 2.69 93 250 5 1,250 62.5 125 $151,038.13
2. Plan activities 3.82 93 355 5 1,775 88.75 177.5 $214,474.14
3. Training 3.47 38 132 5 660 33 66 $79,748.13
4. Creation, testing, research, and development 2.4 1,778 4,266 5 21,330 1,066.5 2,133 $2,577,314.57
5. Gather information, monitor/inspect 1.4 2,102 2,943 5 14,715 735.75 1,471.5 $1,778,020.81
6. Process/compile and review 0.8 50 40 5 200 10 20 $24,166.10
7. Complete reports 11.37 49 557 5 2,785 139.25 278.5 $336,512.94
8. Record/disclose 9.98 49 489 5 2,445 122.25 244.5 $295,430.57
9. Store/file 5.18 51 264 5 1,320 66 132 $159,496.26
TOTAL ANNUAL BURDEN AND COST (rounded) 



53,500 $5,620,000
TOTAL CAPITAL AND O&M COST (rounded)






See Table G-13
GRAND TOTAL (rounded)






$5,620,000









Assumptions:







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







(d) - From previously approved ICR.







Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.







See Attachment I for assumptions and further description of activities.








Sheet 34: Table G-13

Table G-13: Annual Respondent Burden and Cost for Existing Sources Subject to the HON












108.28 144.33 53.34
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Average hours per activity Number of activities per year per respondent Technical hours per year per respondent a Technical hours per year per respondent for wastewater a Estimated technical hours per year
(E=Cx265+Dx80)
Estimated managerial hours per year
(F=Ex0.05)
Estimated clerical hours per year
(G=Ex0.1)
Total cost per year ($) b
1. Familiarize with regulatory requirements 3.61 23 69 14 19,405 970.25 1,940.5 $2,344,715.85
2. Plan activities 6.08 13 61 18 17,605 880.25 1,760.5 $2,127,220.95
3. Training 5.25 4 17 4 4,825 241.25 482.5 $583,007.16
4. Creation, testing, research, and development 17.85 99 1,617 150 440,505 22,025.25 44,050.5 $53,226,439.40
5. Gather information, monitor/inspect 2.5 677 1,693 0 448,645 22,432.25 44,864.5 $54,209,999.67
6. Process/compile and review 20 1 20 0 5,300 265 530 $640,401.65
7. Complete reports 81.2 5 388 18 104,260 5,213 10,426 $12,597,787.93
8. Record/disclose 17.46 26 442 12 118,090 5,904.5 11,809 $14,268,873.75
9. Store/file 6.77 35 222 15 60,030 3,001.5 6,003 $7,253,454.92
TOTAL ANNUAL BURDEN AND COST (rounded) 



1,400,000 $147,000,000
TOTAL CAPITAL AND O&M COST (rounded)






$74,400,000
GRAND TOTAL (rounded)






$221,000,000









Assumptions:







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







(c) - there are 265 existing sources out of the 345 total that will continue to comply with the HON.







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







Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.







See Attachment I for assumptions and further description of activities.








Sheet 35: Capital and O&M Costs

Capital and O&M Costs for Referencing Subparts
















(A) (B) (C) (D) (E) (F) (G)

Subpart Capital/ Startup Cost for One Respondent Number of New Respondents with Capital/ Startup Costs Total Capital/ Startup Cost,
(B X C)
Annual O&M Costs for One Respondent Number of Respondents with O&M Total O&M,
(E X F)


NSPS Ka $0 0 $0 $0 0 $0

Subtotal $0

NSPS Kb $13,500 2 $27,000 $1,350 438 $591,300

Subtotal $618,000

NSPS VV $0 0 $0 $0 0 $0

Subtotal $0

NSPS VVa $1,400 3 $4,200 $0 0 $0

Subtotal $4,200
2053
NSPS DDD $30,000 10 $300,000 $7,000 150 $1,050,000
2068
Subtotal $1,350,000

NSPS III $13,500 1 $13,500 $1,350 17 $22,950

Subtotal $36,500

NSPS NNN $13,500 177 $2,389,500 $1,350 2,407 $3,249,450

Subtotal $5,640,000

NSPS RRR $25,000 20 $500,000 $500 275 $137,500

Subtotal $638,000

NESHAP BB $0 0 $0 $0 0 $0

Subtotal $0

NESHAP Y $0 0 $0 $0 0 $0

Subtotal $0

NESHAP V $0 0 $0 $0 0 $0

Subtotal $0

NESHAP F $0 0 $0 $0 0 $0

Subtotal $0

NESHAP G $25,000 5 $125,000 $275,000 270 $74,250,000

Subtotal $74,400,000

NESHAP H $1,400 9 $12,600 $0 0 $0

Subtotal $12,600

NESHAP I $0 0 $0 $0 0 $0

Subtotal $0

CAR $0 0 $0 $275,000 80 $22,000,000

Subtotal $22,000,000

CAR Revisions $0 0 $0 $0 0 $0

Subtotal $0

Total for CAR and Referencing Subparts $105,000,000


Sheet 36: Number of Respondents

Number of Respondents

Respondents That Submit Reports Respondents That Do Not Submit Any Reports

(A) (B) (C) (D) (E)
Year Number of New Respondents 1 Number of Existing Respondents Number of Existing Respondents that keep records but do not submit reports Number of Existing Respondents That Are Also New Respondents Number of Respondents
(E=A+B+C-D)
NSPS Ka
1 0 174 0 0 174
2 0 174 0 0 174
3 0 174 0 0 174
Average 0 174 0 0 174
NSPS Kb
1 37 728 0 0 765
2 37 765 0 0 802
3 37 802 0 0 839
Average 37 765 0 0 802
NSPS VV
1 0 436 0 0 436
2 0 436 0 0 436
3 0 436 0 0 436
Average 0 436 0 0 436
NSPS VVa
1 38 380 0 0 418
2 38 418 0 0 456
3 38 456 0 0 494
Average 38 418 0 0 456
NSPS DDD
1 10 130 0 0 140
2 10 140 0 0 150
3 10 150 0 0 160
Average 10 140 0 0 150
NSPS III
1 1 15 0 0 16
2 1 16 0 0 17
3 1 17 0 0 18
Average 1 16 0 0 17
NSPS NNN
1 177 2053 0 0 2230
2 177 2230 0 0 2407
3 177 2407 0 0 2584
Average 177 2230 0 0 2407
NSPS RRR
1 20 235 0 0 255
2 20 255 0 0 275
3 20 275 0 0 295
Average 20 255 0 0 275
NESHAP BB
1 0 54 0 0 54
2 0 54 0 0 54
3 0 54 0 0 54
Average 0 54 0 0 54
NESHAP Y
1 0 4 0 0 4
2 0 4 0 0 4
3 0 4 0 0 4
Average 0 4 0 0 4
NESHAP V
1 2 63 0 0 65
2 2 65 0 0 67
3 2 67 0 0 69
Average 2 65 0 0 67
HON
1 5 260 0 0 265
2 5 265 0 0 270
3 5 270 0 0 275
Average 5 265 0 0 270
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