| Table 1.1: Annual Respondent Burden and Cost – NESHAP for Source Categories: Gasoline Distribution Bulk Terminals, Bulk Plants, Pipeline Facilities, and Gasoline Dispensing Facilities (40 CFR Part 63, Subparts BBBBBB and CCCCCC) |
|
|
|
|
|
|
|
|
|
|
|
June 2017: |
|
112.98 |
149.35 |
54.81 |
|
| Burden item |
(A) Person hours per occurrence |
(B) No. of occurrences per respondent per year |
(C) Person hours per respondent per year (C=AxB) |
(D) Respondents per year a |
(E) Technical person- hours per year (E=CxD) |
(F) Management person hours per year (Ex0.05) |
(G) Clerical person hours per year (Ex0.1) |
(H) Total Cost per year b |
| 1.1 Bulk Terminals |
|
|
|
|
|
|
|
|
| (a) Familiarization with rule requirements |
6 |
1 |
6 |
1,100 |
6600 |
330 |
660 |
$831,128.10 |
| (b) Prepare Initial Notification c |
4 |
0 |
4 |
0 |
0 |
0 |
0 |
0 |
| (c) Perform Initial Performance Test c |
175 |
0 |
175 |
0 |
0 |
0 |
0 |
0 |
| (d) Prepare Notification of Compliance Status c |
4 |
0 |
4 |
0 |
0 |
0 |
0 |
0 |
| (e) Perform annual storage tank inspection d |
12 |
1 |
12 |
1,100 |
13,200 |
660 |
1320 |
$1,662,256.20 |
| (f) Perform equipment leak inspections d |
2 |
12 |
24 |
1,100 |
26,400 |
1,320 |
2,640 |
$3,324,512.40 |
| (g) Keep records of performance tests, storage tank and equipment leak inspections, and cargo tank vapor tightness documentation |
0.75 |
12 |
9 |
1,100 |
9,900 |
495 |
990 |
$1,246,692.15 |
| (h) Submit semiannual compliance report |
4 |
2 |
8 |
1,100 |
8,800 |
440 |
880 |
$1,108,170.80 |
| Subtotal Reporting [(h)] |
|
|
|
|
10,120 |
$1,108,171 |
| Subtotal Recordkeeping [(e) - (g)] |
|
|
|
|
64,515 |
$7,064,589 |
| TOTAL LABOR BURDEN AND COST (rounded)e |
|
|
|
|
74,600 |
$8,170,000 |
| TOTAL CAPITAL AND O&M COST (rounded)e |
|
|
|
|
|
$110,000 |
| GRAND TOTAL (rounded)e |
|
|
|
|
74,600 |
$8,280,000 |
|
|
|
|
|
|
|
|
|
| Assumptions for Table 1.1: |
|
|
|
|
|
|
|
|
| a We expect no new affected sources the next 3 years of this ICR. Therefore, the estimated number of respondents remains unchanged as 1,100 existing bulk terminals. |
|
|
|
|
|
|
|
|
| b This ICR uses the following labor rates: $149.35 per hour for Executive, Administrative, and Managerial labor; $112.98 per hour for Technical labor, and $54.81 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2017, “Table 2: Civilian Workers, by Occupational and Industry group.” The rates are from column 1, “Total Compensation.” The rates have been increased by 110% to account for the benefit packages available to those employed by private industry. |
| c Preparing Initial Notification, performing initial performance test, and preparing Notification of Compliance Status are one-time activities. |
|
|
|
|
|
|
|
|
| d Assumed that all respondents are currently performing annual storage tank inspections; and, that all are currently performing equipment leak inspections at least once per month. |
|
|
|
|
|
|
|
|
| e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
|
|
|
|
|
|
|
|
| Table 1.2: Annual Respondent Burden and Cost – NESHAP for Source Categories: Gasoline Distribution Bulk Terminals, Bulk Plants, Pipeline Facilities, and Gasoline Dispensing Facilities (40 CFR Part 63, Subparts BBBBBB and CCCCCC) (Renewal) |
|
|
|
|
|
|
|
|
|
|
|
June 2017: |
|
112.98 |
149.35 |
54.81 |
|
| Burden item |
(A) Person hours per occurrence |
(B) No. of occurrences per respondent per year |
(C) Person hours per respondent per year (C=AxB) |
(D) Respondents per year a |
(E) Technical person- hours per year (E=CxD) |
(F) Management person hours per year (Ex0.05) |
(G) Clerical person hours per year (Ex0.1) |
(H) Total Cost per year b |
| 1.2 Pipeline Breakout Stations |
|
|
|
|
|
|
|
|
| (a) Familiarization with rule requirements |
6 |
1 |
6 |
460 |
2760 |
138 |
276 |
$347,562.66 |
| (b) Prepare Initial Notificationc |
8 |
1 |
8 |
0 |
0 |
0 |
0 |
0 |
| (c) Prepare Notification of Compliance Statusc |
8 |
1 |
8 |
0 |
0 |
0 |
0 |
0 |
| (d) Perform annual storage tank inspectiond |
12 |
1 |
12 |
460 |
5,520 |
276 |
552 |
$695,125.32 |
| (e) Perform equipment leak inspectionsd |
2 |
12 |
24 |
460 |
11040 |
552 |
1104 |
$1,390,250.64 |
| (f) Keep records of storage tank and equipment leak inspectionsd |
16 |
1 |
16 |
460 |
7,360 |
368 |
736 |
$926,833.76 |
| (g) Submit semiannual compliance report |
4 |
2 |
8 |
460 |
3,680 |
184 |
368 |
$463,416.88 |
| Subtotal Reporting [(g)] |
|
|
|
|
4,232 |
$463,417 |
| Subtotal Recordkeeping [(d) - (f)] |
|
|
|
|
30,682 |
$3,359,772 |
| TOTAL LABOR BURDEN AND COST (rounded)e |
|
|
|
|
34,900 |
$3,820,000 |
| TOTAL CAPITAL AND O&M COST (rounded)e |
|
|
|
|
|
|
|
$0 |
| GRAND TOTAL (rounded)e |
|
|
|
|
34,900 |
$3,820,000 |
| Assumptions for Table 1.2: |
|
|
|
|
|
|
|
|
| a We expect no new affected sources the next 3 years of this ICR. Therefore, the estimated number of respondents remains unchanged as 460 existing pipeline breakout stations. |
|
|
|
|
|
|
|
|
| b This ICR uses the following labor rates: $149.35 per hour for Executive, Administrative, and Managerial labor; $112.98 per hour for Technical labor, and $54.81 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2017, “Table 2: Civilian Workers, by Occupational and Industry group.” The rates are from column 1, “Total Compensation.” The rates have been increased by 110% to account for the benefit packages available to those employed by private industry. |
| c Preparing Initial Notification, performing initial performance test, and preparing Notification of Compliance Status are one-time activities. |
|
|
|
|
|
|
|
|
| d Assumed that all respondents are currently performing annual storage tank inspections; and, that all are currently performing equipment leak inspections at least once per month. |
|
|
|
|
|
|
|
|
| e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
|
|
|
|
|
|
|
|
| Table 1.3: Annual Respondent Burden and Cost – NESHAP for Source Categories: Gasoline Distribution Bulk Terminals, Bulk Plants, Pipeline Facilities, and Gasoline Dispensing Facilities (40 CFR Part 63, Subparts BBBBBB and CCCCCC) (Renewal) |
|
|
|
|
|
|
|
|
|
|
|
|
June 2017: |
|
112.98 |
149.35 |
54.81 |
|
Increase: Updated Labor Rates |
| Burden item |
(A) Person hours per occurrence |
(B) No. of occurrences per respondent per year |
(C) Person hours per respondent per year (C=AxB) |
(D) Respondents per year a |
(E) Technical person- hours per year (E=CxD) |
(F) Management person hours per year (Ex0.05) |
(G) Clerical person hours per year (Ex0.1) |
(H) Total Cost per year b |
|
| 1.3 Pipeline Pumping Stations |
|
|
|
|
|
|
|
|
|
| (a) Familiarization with rule requirements |
4 |
1 |
4 |
1,800 |
7200 |
360 |
720 |
$906,685.20 |
|
| (b) Prepare Initial Notificationc |
1 |
1 |
1 |
0 |
0 |
0 |
0 |
0 |
|
| (c) Prepare Notification of Compliance Statusc |
1 |
1 |
1 |
0 |
0 |
0 |
0 |
0 |
|
| (d) Perform equipment leak inspections |
1 |
12 |
12 |
1,800 |
21,600 |
1,080 |
2,160 |
$2,720,055.60 |
|
| (e) Keep records of equipment leak inspectionsd |
0.1 |
12 |
1.2 |
1,800 |
2,160 |
108 |
216 |
$272,005.56 |
|
| (f) Submit semiannual compliance report e |
0.25 |
2 |
0.5 |
36 |
18 |
0.9 |
1.8 |
$2,266.71 |
|
| Subtotal Reporting [(f)] |
|
|
|
|
21 |
$2,267 |
|
| Subtotal Recordkeeping [(d) - (e)] |
|
|
|
|
35,604 |
$3,898,746 |
|
| TOTAL LABOR BURDEN AND COST (rounded)f |
|
|
|
|
35,600 |
$3,900,000 |
|
| TOTAL CAPITAL AND O&M COST (rounded)f |
|
|
|
|
|
|
|
$0 |
|
| GRAND TOTAL (rounded)f |
|
|
|
|
35,600 |
$3,900,000 |
|
| Assumptions for Table 1.3: |
|
|
|
|
|
|
|
|
|
| a We expect no new affected sources the next 3 years of this ICR. Therefore, the estimated number of respondents remains unchanged as 1,800 existing pipeline pumping stations. |
|
|
|
|
|
|
|
|
|
| b This ICR uses the following labor rates: $149.35 per hour for Executive, Administrative, and Managerial labor; $112.98 per hour for Technical labor, and $54.81 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2017, “Table 2: Civilian Workers, by Occupational and Industry group.” The rates are from column 1, “Total Compensation.” The rates have been increased by 110% to account for the benefit packages available to those employed by private industry. |
| c Preparing Initial Notification, performing initial performance test, and preparing Notification of Compliance Status are one-time activities. |
|
|
|
|
|
|
|
|
|
| d Assumed that all respondents are currently performing equipment leak inspections at least once per month. |
|
|
|
|
|
|
|
|
|
| e Assumed that, on an annual average basis, 2 percent of facilities (36) will be required to submit a semiannual compliance report because of delays in repairing equipment leaks. |
|
|
|
|
|
|
|
|
|
| f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
|
|
|
|
|
|
|
|
|
| Table 1.4: Annual Respondent Burden and Cost – NESHAP for Source Categories: Gasoline Distribution Bulk Terminals, Bulk Plants, Pipeline Facilities, and Gasoline Dispensing Facilities (40 CFR Part 63, Subparts BBBBBB and CCCCCC) (Renewal) |
|
|
|
|
|
|
|
|
|
|
|
June 2017: |
|
112.98 |
149.35 |
54.81 |
|
| Burden item |
(A) Person hours per occurrence |
(B) No. of occurrences per respondent per year |
(C) Person hours per respondent per year (C=AxB) |
(D) Respondents per year a |
(E) Technical person- hours per year (E=CxD) |
(F) Management person hours per year (Ex0.05) |
(G) Clerical person hours per year (Ex0.1) |
(H) Total Cost per year b |
| 1.4 Bulk Plants |
|
|
|
|
|
|
|
|
| (a) Familiarization with rule requirements (in States without submerged fill rules) |
Tracy Curtis:
Previously 4
2 |
1 |
2 |
1475 |
2950 |
147.5 |
295 |
371489.075 |
| (b) Familiarization with rule requirements (in States with submerged fill rules) |
2 |
1 |
2 |
4,425 |
8850 |
442.5 |
885 |
$1,114,467.23 |
| (c) Prepare Initial Notificationc |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
0 |
| (d) Prepare Notification of Compliance Statusc |
1 |
1 |
1 |
0 |
0 |
0 |
0 |
0 |
| (e) Perform equipment leak inspectionsd |
0.25 |
12 |
3 |
5,900 |
17,700 |
885 |
1,770 |
$2,228,934.45 |
| (f) Keep records of equipment leak inspectionsd |
0.1 |
12 |
1.2 |
5,900 |
7,080 |
354 |
708 |
$891,573.78 |
| (g) Submit semiannual compliance reporte |
1 |
2 |
2 |
118 |
236 |
11.8 |
23.6 |
$29,719.13 |
| Subtotal Reporting [(g)] |
|
|
|
|
271 |
$29,719 |
| Subtotal Recordkeeping [(e) - (f)] |
|
|
|
|
42,067 |
$4,606,465 |
| TOTAL LABOR BURDEN AND COST (rounded)f |
|
|
|
|
42,300 |
$4,640,000 |
| TOTAL CAPITAL AND O&M COST (rounded)f |
|
|
|
|
|
|
|
$0 |
| GRAND TOTAL (rounded)f |
|
|
|
|
42,300 |
$4,640,000 |
|
|
|
|
|
|
|
|
|
| Assumptions for Table 1.4: |
|
|
|
|
|
|
|
|
| a We expect no new affected sources the next 3 years of this ICR. Therefore, the estimated number of respondents remains unchanged as 5,900 existing bulk plants. |
|
|
|
|
|
|
|
|
| b This ICR uses the following labor rates: $149.35 per hour for Executive, Administrative, and Managerial labor; $112.98 per hour for Technical labor, and $54.81 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2017, “Table 2: Civilian Workers, by Occupational and Industry group.” The rates are from column 1, “Total Compensation.” The rates have been increased by 110% to account for the benefit packages available to those employed by private industry. |
| c Preparing Initial Notification, and preparing Notification of Compliance Status are one-time activities. Note: 25% of the respondents are in States without bulk plant rules and 75% are in States with rules. |
| d Assumed that all respondents are currently performing equipment leak inspections at least once per month. |
|
|
|
|
|
|
|
|
| e Assumed that, on an annual average basis, 2 percent of facilities (118) will be required to submit a semiannual compliance report because of delays in repairing equipment leaks. |
|
|
|
|
|
|
|
|
| f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
|
|
|
|
|
|
|
|
| Table 1.5: Annual Respondent Burden and Cost – NESHAP for Source Categories: Gasoline Distribution Bulk Terminals, Bulk Plants, Pipeline Facilities, and Gasoline Dispensing Facilities (40 CFR Part 63, Subparts BBBBBB and CCCCCC) (Renewal) |
|
|
|
|
|
|
|
|
|
|
|
June 2017: |
|
112.98 |
149.35 |
54.81 |
|
| Burden item |
(A) Person hours per occurrence |
(B) No. of occurrences per respondent per year |
(C) Person hours per respondent per year (C=AxB) |
(D) Respondents per year a |
(E) Technical person- hours per year (E=CxD) |
(F) Management person hours per year (Ex0.05) |
(G) Clerical person hours per year (Ex0.1) |
(H) Total Cost per year b |
| 1.5 Gasoline Dispensing Facilities |
|
|
|
|
|
|
|
|
| (a) Familiarization with rule requirements (facilities >100k already in compliance) |
0.5 |
1 |
0.5 |
9,860 |
4,930 |
246.5 |
493 |
$620,827.51 |
| (b) Familiarization with rule requirements (facilities <100k already in compliance) |
0.25 |
0.33 |
0.08 |
0 |
0.0 |
0 |
0 |
$0 |
| (c) Initial vapor balance system testing |
6 |
1 |
6 |
0 |
0 |
0 |
0 |
0 |
| (d) Prepare Initial Notificationc |
1 |
1 |
1 |
0 |
0 |
0 |
0 |
0 |
| (d) Prepare Notification of Compliance Statusc |
1 |
1 |
1 |
0 |
0 |
0 |
0 |
0 |
| (e) Vapor balance system testing d |
6 |
0.3 |
1.8 |
9,860 |
17,748 |
887.4 |
1,774.8 |
$2,234,979.02 |
| Subtotal Reporting [(e)] |
|
|
|
|
20,410 |
$2,234,979 |
| Subtotal Recordkeeping [NA] |
|
|
|
|
5,670 |
$620,828 |
| TOTAL LABOR BURDEN AND COST (rounded)e |
|
|
|
|
26,100 |
$2,860,000 |
| TOTAL CAPITAL AND O&M COST (rounded)e |
|
|
|
|
|
|
|
$0 |
| GRAND TOTAL (rounded)e |
|
|
|
|
26,100 |
$2,860,000 |
|
|
|
|
|
|
|
|
|
| Assumptions for Table 1.5: |
|
|
|
|
|
|
|
|
| a We expect no new affected sources the next 3 years of this ICR. Of the total 340,000 facilities, 243,587 facilities with throughputs of <100,000 gpm that are complying with a SLT submerged fill requirement, and for the 85,340 facilities with throughputs of >100,000 gpm that are complying with a state (SLT) vapor balancing requirement, there are no other reporting or recordkeeping requirements associated with this rule for this ICR. Therefore, the estimated number of respondents with recordkeeping and reporting requirements remains unchanged from the previous ICR as 11,073 gasoline dispensing facilities, of which 9,860 install vapor balance system and 1,213 must add submerged filled as a result of this rulemaking. |
| b This ICR uses the following labor rates: $149.35 per hour for Executive, Administrative, and Managerial labor; $112.98 per hour for Technical labor, and $54.81 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2017, “Table 2: Civilian Workers, by Occupational and Industry group.” The rates are from column 1, “Total Compensation.” The rates have been increased by 110% to account for the benefit packages available to those employed by private industry. |
| c Preparing Initial Notification, conducting an initial vapor balance system test, and preparing Notification of Compliance Status are one-time activities. |
|
|
|
|
|
|
|
|
| d Assume vapor balance pressure retesting require every three years. There are 9,860 gasoline dispensing facilities would have to retest. |
|
|
|
|
|
|
|
|
| e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
|
|
|
|
|
|
|
|
| Table 1.6: Annual Respondent Burden and Cost – NESHAP for Source Categories: Gasoline Distribution Bulk Terminals, Bulk Plants, Pipeline Facilities, and Gasoline Dispensing Facilities (40 CFR Part 63, Subparts BBBBBB and CCCCCC) (Renewal) |
|
|
|
|
|
|
|
| Burden Item |
Average Number of Respondents per year |
Total person-hours per year |
Total Cost per year |
| Subtotal for Reporting Requirements |
19,120 |
35,054 |
$3,838,553 |
| Subtotal for Recordkeeping Requirements |
178,538 |
$19,550,400 |
| TOTAL LABOR BURDEN AND COST |
213,592 |
$23,388,952 |
| TOTAL LABOR BURDEN AND COST (Rounded)a |
|
214,000 |
$23,400,000 |
| TOTAL CAPITAL AND O&M COST(Rounded)a |
|
|
$110,000 |
| GRAND TOTAL (Rounded)a |
|
|
$23,500,000 |
| a Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
31 |
hr per resp |
| Table 2: Average Annual EPA Burden and Cost – NESHAP for Source Categories: Gasoline Distribution Bulk Terminals, Bulk Plants, Pipeline Facilities, and Gasoline Dispensing Facilities (40 CFR Part 63, Subparts BBBBBB and CCCCCC) (Renewal) |
|
|
|
|
|
|
|
|
|
|
|
|
2017: |
48.08 |
64.8 |
26.02 |
|
| Activity |
(A) EPA person-hours per occurrence |
(B) No. of occurrences per plant per year |
(C) EPA person hours per plant per year (AxB) |
(D) Plants per year a |
(E) Technical person-hours per year (CxD) |
(F) Management person-hours per year (Ex0.05) |
(G) Clerical person-hours per year (Ex0.1) |
(H) Cost, $ b |
| Review of storage tank inspection reports |
4 |
1 |
4 |
1,560 |
6,240 |
312 |
624 |
$336,473.28 |
| Review semiannual compliance reports |
2 |
2 |
4 |
1,714 |
6,856 |
342.8 |
685.6 |
$369,689.23 |
| Review of other, non-routine reportsc |
4 |
1 |
4 |
1,912 |
7,648 |
382.4 |
764.8 |
$412,395.46 |
| TOTAL LABOR BURDEN AND COST (rounded)d |
|
|
|
|
23,900 |
1,120,000 |
|
|
|
|
|
|
|
|
|
| Assumptions for Table 2: |
|
|
|
|
|
|
|
|
| a Number of activities per year is the sum of the number of applicable respondents from Tables 1.1 through 1.5. |
|
|
|
|
|
|
|
|
| b This cost is based on the average hourly labor rate from the Office of Personnel Management (OPM) “2017 General Schedule” which excludes locality rates of pay. |
|
|
|
|
|
|
|
|
| c Assumed that 10 percent of affected facilities industry-wide will submit non-routine reports each year. (19,120 x 10% = 1,912) |
|
|
|
|
|
|
|
|
| d Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
|
|
|
|
|
|
|
|
|
| Capital/Startup vs. Operation and Maintenance (O&M) Costs |
|
|
|
|
|
|
|
| (A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
| Continuous Monitoring Device |
Capital/Startup Cost for One Respondent |
Number of New Respondents |
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) |
|
|
|
|
|
|
|
| CPMS for vapor processors |
$0 |
0 |
$0 |
$1,000 |
110 ( 10% of Bulk Terminals) |
$110,000 |