Burden Calculation Tables

---

Overview

OLD Inputs
MemoTables
YR1
YR2
YR3
summary
EPA_YR1
EPA_YR2
EPA_YR3
EPA summary

---

Sheet 1: OLD Inputs

	All Facilities	Flares		Tanks
		Flare Count	#Facilities	# FXRT beneath VP cutoffs
Number of Existing	177	27	16	171
Number of New	4	0	0	0
Total	181
Leak Detection and Repair Program (Method 21)
Parameter	Capital Cost	Annual Cost
Nationwide Cost	$-	$29,651
Estimate of current uncontrolled OLD FXRT subject to LDAR :		149
# Facilities with applicable tanks		85
AVERAGE PER FACILITY	#DIV/0!	$349
HAP Content Monitoring for tanks less than 5% HAP		Current rule has EPA Method 311 required for initial applicability with <5% HAP. Propose repeating test every 5 years or with tank content changes
Parameter	Value
Number of tanks assumed to be <5% HAP:	90
Once every 5 year testing cost/tank:	$1,257
Total cost every 5 years ($):	$113,126
# Facilities	40	set equal to facilities purchasing VP analyzer
Avg. Cost Per Facility	$2,828
Assumed fraction of tanks <5% HAP that change contents every year	0.02
Estimated tanks per year with retest for <5% HAP content:	2
Total tank retest cost per year:	$2,514
VP Monitoring		Compliance measure: initial and repeating every 5 years or with tank content changes to ensure which control regime the tank falls under (i.e., below or above 95% control thresholds).
Parameter	Value
ASTM D2879 analyzer cost ($)	$7,440
Annualized Analyzer cost ($/yr)	$964
Number of facilities purchasing analyzer:	40	Assumes half of the 79 facilities assumed to be larger OLD will need to purchase an analyzer and may have tanks below regulatory threshold vapor pressures
FXRT>5,000 gallons subject to LDAR because they are below 95% control VP thresholds	91	(Assumes all EFRs and IFRs are at controlled level, no further improvements necessary)
Testing labor cost/tank	$182
Total annual labor cost ($/yr):	$16,538
# Facilities with vapor testing	40	set equal to facilities purchasing VP analyzer
Average annual labor cost per facility ($/yr)	$413
# Retests	2	assume retests occur at separate facilities
Average annual labor cost per retest ($/yr)	$182
Connectors monitoring (leak definition of 500 ppmv)						these costs are not included in burden, but facility count of 180 is
Option	By Model		National
	TCI	Incremental TAC w/o Recovery Credits	No. of Affected Facilities	TCI	Incremental TAC w/o Recovery Credits
Small model requiring admin costs	$3,038	$417	0	$0	$0
Medium model requiring admin costs	$13,693	$6,642	57	$780,497	$378,572
Large model requiring admin costs	$49,209	$11,938	13	$639,711	$155,194
Small model requiring no admin costs	$1,184	$177	105	$124,305	$18,537
Medium model requiring no admin costs	$11,839	$1,765	4	$47,354	$7,062
Large model requiring no admin costs	$47,354	$7,062	1	$47,354	$7,062
		Total	180	$1,639,221	$566,428
		Avg per facility:		$9,110	$3,150
Flare Management Plan - One-time cost		**RLSO indicates paragraph (o) of 63.670 doesn't apply if operators choose to follow provisions of 63.670 to show compliance (which is what we're assuming they'll do), so removed from burden estimate.
Parameter	Value
Cost Per Flare
Total Flares
Avg. Cost Per Facility (16 facilities)
Avg. Cost Per Facility (all existing facilities)
Flare Monitor Costs (costs pulled from Flare Impacts memo)
Monitoring Equipment	Capital Equipment Cost ($/flare)	Annualized Cost ($/yr/flare)	Number of Flares Impacted	Nationwide Capital Equipment Cost ($)	Nationwide Total Annualized Cost ($/yr)	27 flares are at 16 facilities
Engineering Calculation Costs (Dedicated Flares)*	7,000	13,160	27	$189,000	$355,320
Avg. Cost Per Facility				$12,000	$22,000
*We assume that the owner or operator would likely follow the provisions at 40 CFR 63.670(i)(4) and (k)(2)(ii) in order to determine compliance with the flare tip velocity standard on a 15-minute block average basis. These provisions allow use of a continuous pressure/temperature monitoring system and engineering calculations in lieu of the more intricate monitoring options also specified in 40 CFR part 63, subpart CC.
Industry Wages
May 2016 National Industry-Specific Occupational Employment and Wage Estimates
NAICS 325000 - Chemical Manufacturing
Category	Occupation Code	Title	2016 Wage	Loaded Wage
Technical	17-2081	Environmental Engineer	49.95	104.90
Clerical	43-0000	Office and Administrative Support Occupations	20.66	43.39
Managerial	11-9041	Architectural and Engineering Managers	68.36	143.56
https://www.bls.gov/oes/2016/may/naics3_325000.htm
EPA Wages
	Hourly Mean Wage	With Fringe & Overhead
(GS- 12, step 1) - Tech.	29.76	$47.62
(GS- 13, step 5) - Mgmt.	40.1	$64.16
(GS-6, step 3) - Cler.	16.1	$25.76
https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2016/GS_h.pdf
or https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/

---

Sheet 2: MemoTables

Capital/Startup and O&M Costs
(A)	(B)	(C)	(D)	(E)	(F)	(G)
Source & Monitor Type	Capital/Startup Costs for One Respondent	Number of Respondents with Capital/Startup Costs	Total Capital/ Startup Cost (B X C)	Annual Cost (O&M and Capital) for One Respondent	Number of Respondentsa	Total Annual Cost, (E X F)
Storage Tanks - HAP Content
Initial Monitoring	$0	0	$0	$2,828	40	$113,120
Retest	$0	0	$0	$1,257	4	$5,028
Storage Tanks - Vapor Pressure
Monitor	$7,440	40	$297,600	$964	53	$51,066
Initial Monitoring	$0	0	$0	$413	40	$16,520
Retest	$0	0	$0	$182	4	$728
Flare Monitors	$12,000	16	$192,000	$22,000	21	$462,000
TOTAL			$489,600			$648,462
(a) Within a given year, there are a maximum of 40 respondents for storage tanks and 16 respondents for flares, however the values in column F reflect the sum of these respondents for years 2 and 3.
Total Annual Responses
(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
Notification of Compliance Status
Storage Tanks	40	1	0	40
Connectors	180	1	0	180
Flares	16	1	0	16
Periodic Reports
Storage Tanks	53	2	0	106
Connectors	240	2	0	480
Flares	21	2	0	42
TOTAL				864

---

Sheet 3: YR1

Table 1 - Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the Organic Liquid Distribution (Non-Gasoline) RTR - Year 1
Burden Item	(A) Respondent Hours per Occurrence (Technical hours)	(B) Non-Labor Costs Per Occurrence	(C) Number of Occurrences Per Respondent Per Year	(D) Technical Hours per Respondent Per Year (A X C)	(E) Number of Respondents Per Year	(F) Technical Hours per Year (D X E)	(G) Clerical Hours per Year (F X 0.1)	(H) Management Hours per Year (F X .05)	(I) Total Hours per Year (F + G + H)	(J) Total Labor Costs Per Year	(K) Total Non-Labor Costs Per Year (B x C x E)	(L) Total Number of Responses per Year (C X E)	Footnotes
1. Applications	NA
2. Surveys and Studies	NA
3. Reporting Requirements
A. Read Rule	24	$0	1	24	181	4,344	434	217	4,996	$505,691	$0	0	a, b
B. Required Activities
1. Storage Tanks
a. HAP Content Monitoring (Method 311)
i. Initial Monitoring	0	$2,828	1	0	0	0	0	0	0	$0	$0	0	c,d
ii. Retest for Changing Tank Contents	0	$1,257	1	0	0	0	0	0	0	$0	$0	0	h
b. VP Monitoring - ASTM D2879 analyzer purchase
i. Capital Cost	0	$7,440	1	0	0	0	0	0	0	$0	$0	0	c,d
ii. Annualized Cost	0	$964	1	0	0	0	0	0	0	$0	$0	0	c,d
c. VP Monitoring
i. Initial Monitoring	0	$413	1	0	0	0	0	0	0	$0	$0	0	c,d
ii. Retest for Changing Tank Contents	0	$182	1	0	0	0	0	0	0	$0	$0	0	h
2. Flare Monitoring
a. Capital Cost	0	$12,000	1	0	0	0	0	0	0	$0	$0	0	c,e,f
b. Annualized Cost	0	$22,000	1	0	0	0	0	0	0	$0	$0	0	c,e,f
C. Create Information	Inc. in 3B
D. Gather Information	Inc. in 3E
E. Report Preparation
1. Notification of Compliance Status
a. Storage Tanks	1	$0	1	1	0	0	0	0	0	$0	$0	0	c,d
b. Connectors	4	$0	1	4	0	0	0	0	0	$0	$0	0	c,g
c. Flares	5	$0	1	5	0	0	0	0	0	$0	$0	0	c,f
2. Compliance Report
a. Storage Tanks	1	$0	2	2	0	0	0	0	0	$0	$0	0	c,d
b. Connectors	4	$0	2	8	0	0	0	0	0	$0	$0	0	c,g
c. Flares	5	$0	2	10	0	0	0	0	0	$0	$0	0	c,f
Reporting Subtotal						4,344	434	217	4,996	$505,691	$0	0
4. Recordkeeping Requirements
A. Read Instructions	Inc. in 3.A
B. Implement Activities	NA
C. Develop Record System	NA
D. Record information
1. Storage Tanks	5	$0	1	5	0	0	0	0	0	$0	$0	0	c,d
2. Connectors	8	$0	1	8	0	0	0	0	0	$0	$0	0	c,g
3. Flares	0.4	$0	365	146	0	0	0	0	0	$0	$0	0	c,f
4. Flow events from bypass lines	25	$0	1	25	0	0	0	0	0	$0	$0	0	i
E. Personnel Training	16	$0	1	16	181	2,896	290	145	3,330	$337,127	$0	0
F. Time for Audits	NA
Recordkeeping Subtotal						2,896	290	145	3,330	$337,127	$0	0
TOTAL						7,240	724	362	8,326	$842,818	$0	0
								Total Hours	Labor	Non-Labor	Total
					Summary of Respondent Burden			8,326	$842,818	$0	$842,818
					Initial Capital and Startup						$505,691
					Annualized Capital/Start-up and O & M						$0
Footnotes:
(a) There are 177 currently operating facilities, and 4 facilities are expected to commence operations within three years after promulgation of the rule. As such, costs are estimated for 181 facilities.
(b) This is a one-time cost (e.g., to read rule or develop plan).
(c) Assumed facilities will read the rule and perform certain one-time activities (e.g., personnel training) in year 1. Assumed that one-third of the facilities would begin complying in year 2 and the remaining two-thirds of the facilities in year 3.
(d) Assumed 40 facilities would have storage tanks applicable to HAP content monitoring and vapor pressure monitoring requirements.
(e) Flare monitoring includes costs for continuous pressure/temperature monitoring system and engineering calculations in lieu of the more intricate monitoring options (e.g. H2 analyzer, calorimeter, flare gas flow monitor, steam controls/flow monitor, and air controls/flow monitor).
(f) 16 facilities have flares applicable to monitoring requirements.
(g) 180 facilities are subject to connector monitoring requirements.
(h) Assumed 2 tanks (i.e., facilities) would change tanks contents within a year.
(i) Assumed that bypass lines were not used during the 3-year period, so costs for bypass lines would not be incurred.

---

Sheet 4: YR2

Table 2 - Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the Organic Liquid Distribution (Non-Gasoline) RTR - Year 2
Burden Item	(A) Respondent Hours per Occurrence (Technical hours)	(B) Non-Labor Costs Per Occurrence	(C) Number of Occurrences Per Respondent Per Year	(D) Technical Hours per Respondent Per Year (A X C)	(E) Number of Respondents Per Year	(F) Technical Hours per Year (D X E)	(G) Clerical Hours per Year (F X 0.1)	(H) Management Hours per Year (F X .05)	(I) Total Hours per Year (F + G + H)	(J) Total Labor Costs Per Year	(K) Total Non-Labor Costs Per Year (B x C x E)	(L) Total Number of Responses per Year (C X E)	Footnotes
1. Applications	NA
2. Surveys and Studies	NA
3. Reporting Requirements
A. Read Rule	24	$0	1	24	0	0	0	0	0	$0	$0	0	a, b
B. Required Activities
1. Storage Tanks
a. HAP Content Monitoring (Method 311)
i. Initial Monitoring	0	$2,828	1	0	13	0	0	0	0	$0	$36,764	0	c,d
ii. Retest for Changing Tank Contents	0	$1,257	1	0	2	0	0	0	0	$0	$2,514	0	h
b. VP Monitoring - ASTM D2879 analyzer purchase
i. Capital Cost	0	$7,440	1	0	13	0	0	0	0	$0	$96,720	0	c,d
ii. Annualized Cost	0	$964	1	0	13	0	0	0	0	$0	$12,526	0	c,d
c. VP Monitoring
i. Initial Monitoring	0	$413	1	0	13	0	0	0	0	$0	$5,369	0	c,d
ii. Retest for Changing Tank Contents	0	$182	1	0	2	0	0	0	0	$0	$364	0	h
2. Flare Monitoring
a. Capital Cost	0	$12,000	1	0	5	0	0	0	0	$0	$60,000	0	c,e,f
b. Annualized Cost	0	$22,000	1	0	5	0	0	0	0	$0	$110,000	0	c,e,f
C. Create Information	Inc. in 3B
D. Gather Information	Inc. in 3E
E. Report Preparation
1. Notification of Compliance Status
a. Storage Tanks	1	$0	1	1	13	13	1	1	15	$1,513	$0	13	c,d
b. Connectors	4	$0	1	4	60	240	24	12	276	$27,939	$0	60	c,g
c. Flares	5	$0	1	5	5	25	3	1	29	$2,910	$0	5	c,f
2. Compliance Report
a. Storage Tanks	1	$0	2	2	13	26	3	1	30	$3,027	$0	26	c,d
b. Connectors	4	$0	2	8	60	480	48	24	552	$55,877	$0	120	c,g
c. Flares	5	$0	2	10	5	50	5	3	58	$5,821	$0	10	c,f
Reporting Subtotal						834	83	42	959	$97,087	$167,537	234
4. Recordkeeping Requirements
A. Read Instructions	Inc. in 3.A
B. Implement Activities	NA
C. Develop Record System	NA
D. Record information
1. Storage Tanks	5	$0	1	5	13	65	7	3	75	$7,567	$0	0	c,d
2. Connectors	8	$0	1	8	60	480	48	24	552	$55,877	$0	0	c,g
3. Flares	0.4	$0	365	146	5	730	73	37	840	$84,980	$0	0	c,f
4. Flow events from bypass lines	25	$0	1	25	0	0	0	0	0	$0	$0	0	i
E. Personnel Training	16	$0	1	16	0	0	0	0	0	$0	$0	0
F. Time for Audits	NA
Recordkeeping Subtotal						1,275	128	64	1,466	$148,424	$0	0
TOTAL						2,109	211	105	2,425	$245,511	$167,537	234
								Total Hours	Labor	Non-Labor	Total
					Summary of Respondent Burden			2,425	$245,511	$167,537	$413,048
					Initial Capital and Startup						$156,720
					Annualized Capital/Start-up and O & M						$167,537
Footnotes:
(a) There are 177 currently operating facilities, and 4 facilities are expected to commence operations within three years after promulgation of the rule. As such, costs are estimated for 181 facilities.
(b) This is a one-time cost (e.g., to read rule or develop plan).
(c) Assumed facilities will read the rule and perform certain one-time activities (e.g., personnel training) in year 1. Assumed that one-third of the facilities would begin complying in year 2 and the remaining two-thirds of the facilities in year 3.
(d) Assumed 40 facilities would have storage tanks applicable to HAP content monitoring and vapor pressure monitoring requirements.
(e) Flare monitoring includes costs for continuous pressure/temperature monitoring system and engineering calculations in lieu of the more intricate monitoring options (e.g. H2 analyzer, calorimeter, flare gas flow monitor, steam controls/flow monitor, and air controls/flow monitor).
(f) 16 facilities have flares applicable to monitoring requirements.
(g) 180 facilities are subject to connector monitoring requirements.
(h) Assumed 2 tanks (i.e., facilities) would change tanks contents within a year.
(i) Assumed that bypass lines were not used during the 3-year period, so costs for bypass lines would not be incurred.

---

Sheet 5: YR3

Table 3 - Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the Organic Liquid Distribution (Non-Gasoline) RTR - Year 3
Burden Item	(A) Respondent Hours per Occurrence (Technical hours)	(B) Non-Labor Costs Per Occurrence	(C) Number of Occurrences Per Respondent Per Year	(D) Technical Hours per Respondent Per Year (A X C)	(E) Number of Respondents Per Year	(F) Technical Hours per Year (D X E)	(G) Clerical Hours per Year (F X 0.1)	(H) Management Hours per Year (F X .05)	(I) Total Hours per Year (F + G + H)	(J) Total Labor Costs Per Year	(K) Total Non-Labor Costs Per Year (B x C x E)	(L) Total Number of Responses per Year (C X E)	Footnotes
1. Applications	NA
2. Surveys and Studies	NA
3. Reporting Requirements
A. Read Rule	24	$0	1	24	0	0	0	0	0	$0	$0	0	a, b
B. Required Activities
1. Storage Tanks
a. HAP Content Monitoring (Method 311)
i. Initial Monitoring	0	$2,828	1	0	27	0	0	0	0	$0	$76,356	0	c,d
ii. Retest for Changing Tank Contents	0	$1,257	1	0	2	0	0	0	0	$0	$2,514	0	h
b. VP Monitoring - ASTM D2879 analyzer purchase
i. Capital Cost	0	$7,440	1	0	27	0	0	0	0	$0	$200,880	0	c,d
ii. Annualized Cost	0	$964	1	0	40	0	0	0	0	$0	$38,541	0	c,d
c. VP Monitoring
i. Initial Monitoring	0	$413	1	0	27	0	0	0	0	$0	$11,151	0	c,d
ii. Retest for Changing Tank Contents	0	$182	1	0	2	0	0	0	0	$0	$364	0	h
2. Flare Monitoring
a. Capital Cost	0	$12,000	1	0	11	0	0	0	0	$0	$132,000	0	c,e,f
b. Annualized Cost	0	$22,000	1	0	16	0	0	0	0	$0	$352,000	0	c,e,f
C. Create Information	Inc. in 3B
D. Gather Information	Inc. in 3E
E. Report Preparation
1. Notification of Compliance Status
a. Storage Tanks	1	$0	1	1	27	27	3	1	31	$3,143	$0	27	c,d
b. Connectors	4	$0	1	4	120	480	48	24	552	$55,877	$0	120	c,g
c. Flares	5	$0	1	5	11	55	6	3	63	$6,403	$0	11	c,f
2. Compliance Report
a. Storage Tanks	1	$0	2	2	40	80	8	4	92	$9,313	$0	80	c,d
b. Connectors	4	$0	2	8	180	1440	144	72	1656	$167,632	$0	360	c,g
c. Flares	5	$0	2	10	16	160	16	8	184	$18,626	$0	32	c,f
Reporting Subtotal						2,242	224	112	2,578	$260,994	$480,925	630
4. Recordkeeping Requirements
A. Read Instructions	Inc. in 3.A
B. Implement Activities	NA
C. Develop Record System	NA
D. Record information
1. Storage Tanks	5	$0	1	5	40	200	20	10	230	$23,282	$0	0	c,d
2. Connectors	8	$0	1	8	180	1,440	144	72	1,656	$167,632	$0	0	c,g
3. Flares	0.4	$0	365	146	16	2,336	234	117	2,686	$271,937	$0	0	c,f
4. Flow events from bypass lines	25	$0	1	25	0	0	0	0	0	$0	$0	0	i
E. Personnel Training	16	$0	1	16	0	0	0	0	0	$0	$0	0
F. Time for Audits	NA
Recordkeeping Subtotal						3,976	398	199	4,572	$462,851	$0	0
TOTAL						6,218	622	311	7,151	$723,845	$480,925	630
								Total Hours	Labor	Non-Labor	Total
					Summary of Respondent Burden			7,151	$723,845	$480,925	$1,204,770
					Initial Capital and Startup						$332,880
					Annualized Capital/Start-up and O & M						$480,925
Footnotes:
(a) There are 177 currently operating facilities, and 4 facilities are expected to commence operations within three years after promulgation of the rule. As such, costs are estimated for 181 facilities.
(b) This is a one-time cost (e.g., to read rule or develop plan).
(c) Assumed facilities will read the rule and perform certain one-time activities (e.g., personnel training) in year 1. Assumed that one-third of the facilities would begin complying in year 2 and the remaining two-thirds of the facilities in year 3.
(d) Assumed 40 facilities would have storage tanks applicable to HAP content monitoring and vapor pressure monitoring requirements.
(e) Flare monitoring includes costs for continuous pressure/temperature monitoring system and engineering calculations in lieu of the more intricate monitoring options (e.g. H2 analyzer, calorimeter, flare gas flow monitor, steam controls/flow monitor, and air controls/flow monitor).
(f) 16 facilities have flares applicable to monitoring requirements.
(g) 180 facilities are subject to connector monitoring requirements.
(h) Assumed 2 tanks (i.e., facilities) would change tanks contents within a year.
(i) Assumed that bypass lines were not used during the 3-year period, so costs for bypass lines would not be incurred.

---

Sheet 6: summary

Table 4 - Summary of Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the Organic Liquid Distribution (Non-Gasoline) RTR
Year	Technical Hours	Clerical Hours	Management Hours	Total Labor Hours	Labor Costs	Non-Labor (Annualized Capital/Startup and O&M) Costs	Total Costs
1	7,240	724	362	8,326	$842,818	$0	$842,818
2	2,109	211	105	2,425	$245,511	$167,537	$413,048
3	6,218	622	311	7,151	$723,845	$480,925	$1,204,770
Total	15,567	1,557	778	17,902	$1,812,174	$648,462	$2,460,636
Average	5,189	519	259	5,967	$604,058	$216,154	$820,212
Year	Number of Respondents	Number of Responses	Reporting Hours	Recordkeeping Hours	Total Hours	Hours per Response	Hours Per Respondent
1	181	0	4,996	3,330	8,326	--	46
2	60	234	959	1,466	2,425	10	40
3	180	630	2,578	4,572	7,151	11	40
Total	421	864	8,533	9,369	17,902	21	43
Average	140	288	2,844	3,123	5,967	21	43

---

Sheet 7: EPA_YR1

Table 5 - Annual Agency Burden and Cost of Recordkeeping and Reporting Requirements for the Organic Liquid Distribution (Non-Gasoline) RTR - Year 1
					(A)	(B)	(C)	(D)	(E)	(F)	(G)	Footnotes
Burden Item					Number of Occurrences Per Year	Technical Hours Per Occurrence	Tech Hours Per Year (C=A x B)	Management Hours Per Year (D = C x 0.05)	Clerical Hours Per Year (E = C x 0.1)	Total Hours Per Year (C+D+E)	Total Cost Per Year
1.	Applications				not applicable
2.	Read and Understand Rule Requirements				46	24	1104	55	110	1270	$58,954	a
3.	Required Activities
	A.	Observe stack tests			0	16	0	0	0	0	$0
	B.	Excess emissions -- Enforcement Activities			0	24	0	0	0	0	$0
	C.	Create Information			not applicable
	D.	Gather Information			not applicable
	E.	Report Reviews
		1.	Review notification of compliance status
			a. Storage Tanks		0	2	0	0	0	0	$0
			b. Connectors		0	2	0	0	0	0	$0
			c. Flares		0	2	0	0	0	0	$0
		2.	Review compliance reports				0	0	0	0	$0
			a. Storage Tanks		0	2	0	0	0	0	$0
			b. Connectors		0	2	0	0	0	0	$0
			c. Flares		0	2	0	0	0	0	$0
	F.	Prepare annual summary report			1	10	10	1	1	12	$534
4.	Travel expenses: (1 person * 30 hours per year / 8 hours per day * $75 per diem) + ($600 per round trip) =							$0	per trip		$0
	TOTAL						1114	56	111	1281	$59,488
Footnotes:
a	Number of occurrences is the number of states and EPA Regions with affected sources (36 states + 10 EPA regions = 46 respondents).
																					Percent of Stack Tests Observed			20%
																					Estimated Percent Retesting			10%
																					Estimated Percent Emission Exceedences			10%

---

Sheet 8: EPA_YR2

Table 6 - Annual Agency Burden and Cost of Recordkeeping and Reporting Requirements for the Organic Liquid Distribution (Non-Gasoline) RTR - Year 2
					(A)	(B)	(C)	(D)	(E)	(F)	(G)	Footnotes
Burden Item					Number of Occurrences Per Year	Technical Hours Per Occurrence	Tech Hours Per Year (C=A x B)	Management Hours Per Year (D = C x 0.05)	Clerical Hours Per Year (E = C x 0.1)	Total Hours Per Year (C+D+E)	Total Cost Per Year
1.	Applications				not applicable
2.	Read and Understand Rule Requirements				0	24	0	0	0	0	$0
3.	Required Activities
	A.	Observe stack tests			0	16	0	0	0	0	$0
	B.	Excess emissions -- Enforcement Activities			0	24	0	0	0	0	$0
	C.	Create Information			not applicable
	D.	Gather Information			not applicable
	E.	Report Reviews
		1.	Review notification of compliance status
			a. Storage Tanks		13	2	26	1	3	30	$1,388
			b. Connectors		60	2	120	6	12	138	$6,408
			c. Flares		5	2	10	1	1	12	$534
		2.	Review compliance reports				0	0	0	0	$0
			a. Storage Tanks		26	2	52	3	5	60	$2,777
			b. Connectors		120	2	240	12	24	276	$12,816
			c. Flares		10	2	20	1	2	23	$1,068
	F.	Prepare annual summary report			1	10	10	1	1	12	$534
4.	Travel expenses: (1 person * 30 hours per year / 8 hours per day * $75 per diem) + ($600 per round trip) =							$0	per trip		$0
	TOTAL						478	24	48	550	$25,525
																					Percent of Stack Tests Observed			20%
																					Estimated Percent Retesting			10%
																					Estimated Percent Emission Exceedences			10%

---

Sheet 9: EPA_YR3

Table 7 - Annual Agency Burden and Cost of Recordkeeping and Reporting Requirements for the Organic Liquid Distribution (Non-Gasoline) RTR - Year 3
					(A)	(B)	(C)	(D)	(E)	(F)	(G)	Footnotes
Burden Item					Number of Occurrences Per Year	Technical Hours Per Occurrence	Tech Hours Per Year (C=A x B)	Management Hours Per Year (D = C x 0.05)	Clerical Hours Per Year (E = C x 0.1)	Total Hours Per Year (C+D+E)	Total Cost Per Year
1.	Applications				not applicable
2.	Read and Understand Rule Requirements				0	24	0	0	0	0	$0
3.	Required Activities
	A.	Observe stack tests			0	16	0	0	0	0	$0
	B.	Excess emissions -- Enforcement Activities			0	24	0	0	0	0	$0
	C.	Create Information			not applicable
	D.	Gather Information			not applicable
	E.	Report Reviews
		1.	Review notification of compliance status
			a. Storage Tanks		27	2	54	3	5	62	$2,884
			b. Connectors		120	2	240	12	24	276	$12,816
			c. Flares		11	2	22	1	2	25	$1,175
		2.	Review compliance reports				0	0	0	0	$0
			a. Storage Tanks		80	2	160	8	16	184	$8,544
			b. Connectors		360	2	720	36	72	828	$38,448
			c. Flares		32	2	64	3	6	74	$3,418
	F.	Prepare annual summary report			1	10	10	1	1	12	$534
4.	Travel expenses: (1 person * 30 hours per year / 8 hours per day * $75 per diem) + ($600 per round trip) =							$0	per trip		$0
	TOTAL						1270	64	127	1461	$67,818
																					Percent of Stack Tests Observed			20%
																					Estimated Percent Retesting			10%
																					Estimated Percent Emission Exceedences			10%

---

Sheet 10: EPA summary

Table 8 - Summary of Annual Agency Burden and Cost of Recordkeeping and Reporting Requirements for the Organic Liquid Distribution (Non-Gasoline) RTR
Year	Technical Hours	Management Hours	Clerical Hours	Total Hours	Labor Costs	Non-Labor Costs	Total Costs
1	1,114	56	111	1,281	$59,488	$0	$59,488
2	478	24	48	550	$25,525	$0	$25,525
3	1,270	64	127	1,461	$67,818	$0	$67,818
Total	2,862	143	286	3,291	$152,831	$0	$152,831
Average	954	48	95	1,097	$50,944	$0	$50,944