Burden Calculation Tables

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Overview

Table 1
Table 2

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Sheet 1: Table 1

Table 1: Annual Respondent Burden and Cost – NESHAP for Gasoline Distribution Facilities (40 CFR Part 63, Subpart R) (Renewal)
					120.27	141.06	58.67
Burden Items	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Respondent Hours per Occurrence	Number of Occurrences per Respondent per Year	Hours per Respondent per Year	Number of Respondents per Year a	Technical Hours per Year	Management Hours per Year	Clerical Hours per Year	Total Labor costs per Year ($) b
			(C=AxB)		(E=CxD)	(F=Ex0.05)	(G=Ex0.1)
1. Applications	N/A
2. Survey and Studies	N/A
3. Reporting Requirements
A. Familiarize with regulatory requirements c	1	1	1	102	102	5.1	10.2	$13,585.38
B. Required Activities
a. Initial performance test d	175	1	175	0	0	0	0	$0
b. Repeat of performance test d	175	1	175	0	0	0	0	$0
c. Storage tank seal/seal gap inspections tanks certification e	16	1	16	51	816	40.8	81.6	$108,683.04
d. Annual testing certification of area source compliance status f	1	1	1	390	390	19.5	39	$51,944.10		<-there is no test. An annual report is required.
C. Create Information	See 3B
D. Gather Existing Information	See 3B
E. Write Report d
a. Notification of applicability	3	1	3	0	0	0	0	$0
b. Notification of construction/reconstruction/ modification	2	1	2	0	0	0	0	$0
c. Notification of actual startup	2	1	2	0	0	0	0	$0
d. Notification of performance test	2	1	2	0	0	0	0	$0
e. Notification of CEMS performance evaluation	2	1	2	0	0	0	0	$0
f. Notification of area source compliance status	See 3B.d
g. Report of performance test	See 3B
h. Semiannual compliance reports bulk terminals major sources g	10	2	20	52.2	1,044	52.2	104	$139,050.36
i. Semiannual compliance reports pipeline breakout major sources g	8	2	16	9	144	7.2	14.4	$19,179.36
Subtotal for Reporting Requirements					2,870			$332,442
4. Recordkeeping Requirements
A. Familiarize with regulatory requirements	See 3A
B.  Plan Activities	See 3B&4C
C. Implement Activities
a. Gasoline terminals:
i. File cargo tank inspection records h	0.5	26	13	61.2	796	39.8	79.6	$105,965.96		<- re-lettered these rows
ii. Update cargo tank inspection records h	6	1	6	61.2	367	18.4	36.7	$48,907.37		<- re-lettered these rows
iii. Cross-check cargo tank inspection file h	6	26	156	61.2	9,547	477	955	$1,271,591.57		<- re-lettered these rows
b. Pipeline breakout stations	See 3B									<- re-lettered these rows
D.  Develop Record System i	8	1	8	0	0	0	0	$0
E.  Time to Enter Information
a. Record equipment subject to visual inspection requirements at pipeline breakout stations	1	1	1	0	0	0	0	$0
b. Record equipment leaks data at bulk terminals	0.1	4	0.4	87	34.8	1.74	3.48	$4,635.01
c. Record equipment leaks data at pipeline breakout stations	0.1	12	1.2	15	18	0.9	1.8	$2,397.42
d. Record storage tank seal inspection results e	1	1	1	51	51	2.55	5.1	$6,792.69
e. Records of startups, shutdowns, malfunctions, etc.	1	4	4	51	204	10.2	20.4	$27,170.76
f. Area source recordkeeping j	0.25	1	0.25	390	97.5	4.88	9.75	$12,986.03
F.  Time to train personnel	1	1	1	102	102	5.1	10.2	$13,585.38
G. Time to adjust existing ways to comply with previously applicable requirements	N/A
H. Time to transmit information	See 4E
I.  Time for audits k
a. Bulk gasoline terminals	6	1	6	22	132	6.6	13.2	$17,581.08
b. Pipeline breakout stations	4	1	4	4	16	0.8	1.6	$2,131.04
Subtotal for Recordkeeping Requirements					13,070			$1,513,744
TOTAL ANNUAL BURDEN AND COST (rounded) l					15,900			$1,850,000		28.75226039783	hrs/response
CAPITAL AND O&M COST (rounded) l								$305,000	Updated per revised O&M from SS
GRAND TOTAL (rounded) l								$2,160,000
Assumptions:
a We have estimated that there are 102 major source respondents, (comprised of 87 bulk terminals and 15 pipeline breakout stations), and 390 area source respondents which are major sources of HAPs subject to this NESHAP. We have also estimated that no new respondents will become subject to the regulation in the next three years.													40.8
b This ICR uses the following labor rates: $141.06 per hour for Executive, Administrative, and Managerial labor; $120.27 per hour for Technical labor, and $58.67 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2019, Table 2. Civilian Workers, by occupational and industry group. The rates are from column 1, Total Compensation. The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry.
c We have assumed that all major source respondents will have to familiarize with the regulatory requirements each year.
d These requirements requriments only apply to new respondents. New respondents would have to comply with the initial rule requirements including notifications and performance tests for add-on control devices.
e Performance tests are required for vapor processing and collection systems: Method 27 for pressure, Method 21 for leak detection testing at cargo tanks. Annual certification test for cargo tanks using Methods 21 and 27 is required. However, we have assumed that 50 percent of the major source respondents that are major sources are currently subject to test requirements equivalent to the requirements of Bulk Gasoline Terminal NSPS (40 CFR Part 60, Subpart XX) and Volatile Organic Liquid (VOL) storage NSPS (40 CFR Part 60, Subparts K, Ka, and Kb) or the storage tank EPA Control Technique Guidelines (CTG) for pipeline breakout stations.
f We have estimated that there isare a total of 1,560 area source gasoline distribution facilities (i.e., 1,100 bulk gasoline terminal and 460 pipeline breakout stations), of which 25 percent will be within 50 percent of major source threshold criteria (1,560 x 0.25 = 390). These 390 area source respondents are and will be required to submit an annual report certifying that facility parameters documenting minor source status have not been exceeded. conduct an annual certification testing.
g Respondents that are major sources of HAPs (i.e., 87 bulk terminals and 15 pipeline breakout stations) are required to submit semiannual compliance reports. We have assumed that 60 percent of the major sources (102 x 0.6 = 61.2 respondents, comprised of 52.2 bulk terminals and 9 pipeline breakout stations) would be required to submit semiannual reports under the NESHAP Subpart R since the remaining 40 percent are already complying with similar reporting requirements under NSPS reporting requirements equivalent to the Bulk Gasoline Terminal NSPS (40 CFR Part 60, Subpart XX) for bulk terminals and the VOL storage NSPS (40 CFR Part 60, Subparts K, Ka, and Kb) or storage tank CTG’s for pipeline breakout stations.
h We have assumed that 60 percent of the 102 major source respondents (i.e., 61.2) are required to maintain cargo tank implementation files.
i Assumes that respondents already have the technology and recordkeeping systems in place to monitor daily operations and to comply with existing regulations.
j We have assumed that 25 percent of area source facilities (390) will be required to keep annual records of their area source status using the screening equation.
k We have assumed that 25 percent of major source respondents (22 bulk terminals and 4 pipeline breakout stations) will conduct audits each year.
l Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 2: Table 2

Table 2: Average Annual EPA Burden and Cost – NESHAP for Gasoline Distribution Facilities (40 CFR Part 63, Subpart R) (Renewal)
					49.44	66.62	26.75
Activity	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	EPA Hours per Occurrence	Number of Occurrences per Plant per Year	EPA Hours per Year	Plants per Year a	Technical Hours per Year	Management Hours per Year	Clerical Hours per Year	Costs per Year ($) b
			(C=AxB)		(E=CxD)	(F=Ex0.05)	(G=Ex0.1)
Report Review
Notification of construction/reconstruction	N/A
Notification of actual startup	N/A
Notification of compliance status	10	0	0	0	0	0	0	$0
Notification of applicability	2	0	0	0	0	0	0	$0
Notification of performance test c	2	0	0	0	0	0	0	$0
Notification of CEMS performance evaluation	2	0	0	0	0	0	0	$0
Semiannual compliance reports (major sources) d	10	2	20	61.2	1,224	61	122	$64,591.70
Notification of area source compliance status e	0.5	1	0.5	390	195	9.8	19.5	$10,290.35
TOTAL ANNUAL BURDEN (rounded) f					1,630			$74,900
Assumptions:
a We estimate that there are 102 major source respondents and 390 area source respondents subject to this NESHAP. We have also estimated that no new respondents will become subject to the regulation in the next three years.
b This cost is based on the following hourly labor rates times a 1.6 benefits multiplication factor to account for government overhead expenses: $66.62 for Managerial (GS-13, Step 5, $41.64 x 1.6), $49.44 for Technical (GS-12, Step 1, $30.90 x 1.6) and $26.75 Clerical (GS-6, Step 3, $16.72 x 1.6). These rates are from the Office of Personnel Management (OPM) "2019 General Schedule" which excludes locality rates of pay.
c We assume that existing major source respondents are in compliance with initial rule requirements. New respondents would have to comply with the initial rule requirements including notifications and performance tests for add-on control devices.
d We assume that 60 percent of the 102 major source respondents (102 x 0.6 = 61.2) would be required to submit semiannual reports under the NESHAP Subpart R since the remaining 40 percent are already complying with similar reporting requirements under another applicable NSPS rule.
e We estimate that there are 1,560 area sources (i.e., 1,100 bulk gasoline terminal and 460 pipeline breakout stations), of which 25 percent (1,560 x 0.25 = 390) would be certifying annually that they are below the major source threshold criteria.
f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.