Burden Calculations Tables

1854t11.xlsx

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

Burden Calculations Tables

OMB: 2060-0443

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Overview

Read Me
Number of Respondents
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
Labor


Sheet 1: Read Me

Notes for renewing this ICR:
Compliance with the CAR is a voluntary alternative. Sources may continue to comply with existing applicable rules or may choose to comply with the consolidated rule. All existing sources must be in compliance with the requirements of the CAR and/or its referencing Subparts within three years of the effective date (i.e., promulgation date) of the appropriate standard for the affected source. All new sources must be in compliance with the requirements of the CAR and/or its referencing Subparts upon startup or the promulgation date of standards for an affected source, whichever is later.   
 Assumptions included in ICR No. 1854.07 add: “Compliance with the CAR is a voluntary alternative. Sources may continue to comply with existing applicable rules or may choose to comply with the consolidated rule. When preparing renewals for the CAR, or the referencing subparts, estimates are made of the percentage of existing sources that will opt to comply with the CAR in lieu of the referencing subparts. Because the CAR is designed for, although not limited to, SOCMI facilities, the number of facilities opting to comply with the CAR is based on the estimated number of SOCMI facilities. It is estimated that 25 percent of non-Hazardous Organic NESHAP (HON) sources will opt to comply with the CAR if the per-source burden of complying with the CAR is less than the per-source burden of complying with the referencing subpart. For those referencing subparts for which the per-source burden of complying with the CAR is higher than the per-source burden of complying with the referencing subpart (subparts Ka, Kb, Y, VV, VVa, III, NNN, RRR, and DDD), it is estimated that 5 percent of sources will opt to comply with the CAR. It is also estimated that 25 percent of HON sources will opt to comply with the CAR. It is assumed that all new sources will initially comply with the appropriate referencing subpart.“

Sheet 2: 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 10 0 0 10 OAQPS identified 10 respondents for this subpart that are SOCMI sources.
2 0 10 0 0 10
3 0 10 0 0 10
Average 0 10 0 0 10
NSPS Kb
1 19 394 0 0 413 OAQPS identified 432 respondents for this subpart, adjusted new respondents to 19 to maintain 4.8% growth rate.
2 19 413 0 0 432
3 19 432 0 0 451
Average 19 413 0 0 432
NSPS VV
1 0 170 0 0 170 OAQPS identified 170 respondents for this subpart that are SOCMI sources.
2 0 170 0 0 170
3 0 170 0 0 170
Average 0 170 0 0 170
NSPS VVa
1 5 60 0 0 65 OAQPS identified 60 respondents for this subpart that are SOCMI sources; retained 5 sources per year (maintains prior growth rate).
2 5 65 0 0 70
3 5 70 0 0 75
Average 5 65 0 0 70
NSPS DDD
1 5 68 0 0 73 ECHO lists 68 facilities; retained 5 sources per year (maintains prior growth rate)
2 5 73 0 0 78
3 5 78 0 0 83
Average 5 73 0 0 78
NSPS III
1 1 37 0 0 38 OAQPS identified 37 respondents for this subpart that are SOCMI sources; retained 1 new source per year.
2 1 38 0 0 39
3 1 39 0 0 40
Average 1 38 0 0 39
NSPS NNN
1 9 109 0 0 118 OAQPS identified 109 respondents for this subpart that are SOCMI sources; retained 9 new source per year (maintains prior growth rate).
2 9 118 0 0 127
3 9 127 0 0 136
Average 9 118 0 0 127
NSPS RRR
1 5 59 0 0 64 OAQPS identified 59 respondents for this subpart that are SOCMI sources; retained 5 new source per year (amintains prior growth rate).
2 5 64 0 0 69
3 5 69 0 0 74
Average 5 64 0 0 69
NESHAP BB
1 0 54 0 0 54 No updates, retained prior estimate.
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 No updates, retained prior estimate.
2 0 4 0 0 4
3 0 4 0 0 4
Average 0 4 0 0 4
NESHAP V
1 0 67 0 0 67 No updates, retained prior estimate, but assumed no new sources.
2 0 67 0 0 67
3 0 67 0 0 67
Average 0 67 0 0 67
HON
1 5 175 0 0 180 OAQPS identified ~175 respondents; retained 5 new sources per year. We assume only 25% of these will comply with CAR
2 5 180 0 0 185
3 5 185 0 0 190
Average 5 180 0 0 185

Sheet 3: 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 4: Table 2

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












$49.44 $66.62 $26.75
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Average hours per activity Number of activities per respondent per year Estimated Technical hours per plant per year
(C=AxB)
Sources per year Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) 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 10 181 1,810 90.5 181 $100,357.26
3. Review periodic reports d 4 1 4 45 180 9 18 $9,980.28
TOTAL (rounded) e



2,290 $110,000









Assumptions:







a This ICR uses the following labor rates: $66.62 for managerial, $49.44 for technical, and $26.75 for clerical labor. These rates are from the Office of Personnel Management (OPM), 2019 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 We assume no new sources will opt to comply with the CAR at startup over the next 3 years.
c We estimate 181 equipment leak sources will comply with the CAR (139 from the HON, 23 from subpart VV and 19 from subpart V - see Table 4). Reports for equipment leaks will be submitted semiannually (181 x 2 = 362 per year). See Attachment C for assumptions and further description of activities.
d We estimate 25 percent of the 180 SOCMI facilities, which equals 45 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 5: Table 3

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












$49.44 $66.62 $26.75
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Technical person-hours per occurrence No. of occurrences per respondent per year Technical person-hours per respondent per year
(C=AxB)
Respondents per year Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) a
Report review/filing 1 1 1 6 6 0.3 0.6 $332.68
TOTAL (rounded) b



7 $333









Assumptions:







a This ICR uses the following labor rates: $66.62 for managerial, $49.44 for technical, and $26.75 for clerical labor. These rates are from the Office of Personnel Management (OPM), 2019 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 6: 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

Note to EPA:
Ka 26
The number of affected sources under each reference subpart were adjusted to reflect the revised inventory of
Kb 206
facilities under each subpart.
Y 0
To do so, we backcalculated the number of affected sources per facility using the prior ICR assumptions
Transfer Racks

of whether 5% or 25% of affected sources complied with CAR.
BB 0
For e.g., for subpart Ka, we took 458 tanks/5%/174 respondents to estimate 53 tanks per facility.
Equipment Leaks

Then we applied 53 tanks x 10 facilities (revised inventory) x 5% complying with CAR = 26 affected sources.
V 19
For subparts BB, V, and HON sources, we divided by 25% to match the assumptions in Attachment I.
VV 23

VVa 0

Process Vents


III 2

NNN 4

RRR 2

DDD 3

HON F & G - Storage Vessels 463

HON F & G - Transfer Racks 185

HON H &I -- Equipment Leaks 139

HON F & G - Process Vents 370





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 Based on the number of sources per facility from the most recently approved CAR ICR. Because the CAR is designed for, although not limited to, SOCMI facilities, the number of facilities opting to comply with the CAR is based on the estimated number of SOCMI facilities. It is estimated that 25 percent of non-Hazardous Organic NESHAP (HON) sources will opt to comply with the CAR if the per-source burden of complying with the CAR is less than the per-source burden of complying with the referencing subpart. For those referencing subparts for which the per-source burden of complying with the CAR is higher than the per-source burden of complying with the referencing subpart (subparts Ka, Kb, Y, VV, VVa, III, NNN, RRR, and DDD), it is estimated that 5 percent of sources will opt to comply with the CAR. It is also estimated that 25 percent of HON sources will opt to comply with the CAR.

Sheet 7: 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 1,105 1.1 765 1.1 204 2.5 348 1 42 1.8 81.0 2,543
2. Plan activities 2.1 800 1.7 1,182 0.85 157 0.57 79 0.23 9.7 4.5 203 2,430
3. Training 1.3 495 0.5 348 0.5 93 0 0 0 0 0 0 935
4. Creation, testing, research and development 28 10,668 16 11,120 16 2,960 380 52,820 155 6,510 0 0 84,078
5. Gather information, monitor/ inspect 14 5,334 17 11,815 17 3,145 263 36,557 108 4,536 54 2,430 63,817
6. Process/compile and review 0 0 0 0 0 0 0 0 0 0 18 810 810
7. Complete forms 9 3,429 5.4 3,753 5.4 999 57 7,923 23 966 5.4 243 17,313
8. Record/disclose 28 10,668 2.8 1,946 2.8 518 4.7 653 1.9 79.8 9 405 14,270
9. Store/file 3 1,143 1.25 869 1.25 231 2.75 382 0.9 37.8 1.58 71.1 2,734
TOTAL 88 33,642 46 31,796 45 8,307 711 98,762 290 12,181 94 4,243 188,931














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 - 381












- storage vessels - 695












- transfer racks - 185












- equipment leaks with connector monitoring - 139












- equipment leaks without connector monitoring - 42












- facilities (used for inventory estimate) - 45












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 8: Table 6

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











$120.27 $141.06 $58.67

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 2.46 23 56.5 2,543 127 254 $338,755.45
2. Plan activities 4.2 13 54.0 2,430 122 243 $323,683.67
3. Training 5.20 4 20.8 935 46.8 93.5 $124,572.61
4. Creation, testing, research, and development 18.9 99 1,868 84,078 4,204 8,408 $11,198,348.82
5. Gather information, monitor/inspect 2.1 677 1,418 63,817 3,191 6,382 $8,499,786.23
6. Process/compile and review 18 1 18.0 810 40.5 81 $107,883.90
7. Complete forms 76.9 5 385 17,313 866 1,731 $2,305,918.47
8. Record/disclose 12.2 26 317 14,270 714 1,427 $1,900,634.62
9. Store/file 1.74 35 60.8 2,734 137 273 $364,161.44
TOTAL LABOR BURDEN AND COST (rounded) c


217,000 $25,200,000
TOTAL CAPITAL AND O&M COST (rounded) c





$12,400,000
GRAND TOTAL (rounded) c





$37,600,000









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 45 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 for privately-owned sources: $141.06 for managerial, $120.27 for technical, and $58.67 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.
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 9: Table 7

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












$120.27 $141.06 $58.67
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Technical person-hours per occurrence No. of occurrences per respondent per year Technical person-hours per respondent per year
(C=AxB)
Respondents per year Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) 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 $399.57
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 $399.57
Subtotal for Reporting Requirements



7 $799
5. Recordkeeping requirements







A. Familiarize with regulatory requirements See 4A






Subtotal for Recordkeeping Requirements



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



7 $799
TOTAL CAPITAL AND O&M COST (rounded) c






$0
GRAND TOTAL (rounded) c






$799









Assumptions:







a This ICR uses the following labor rates for privately-owned sources: $141.06 for managerial, $120.27 for technical, and $58.67 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.
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 10: 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 10 11.33 42 2,638 2,680 $310,376 7 $323 $0 $0
NSPS Kb 432 1,328 15,577 43,220 58,797 $6,809,746 596 $28,739 $316,366 $13,500
NSPS VV 170 340 1,760 15,640 17,400 $2,015,165 782 $37,703 $0 $0
NSPS VVa 70 152 1,121 6,681 7,803 $903,668 419 $20,182 $0 $1,400
NSPS DDD 78 168 3,108 846 3,954 $457,941 414 $19,961 $546,000 $150,000
NSPS III 39 80 396 418 814 $94,285 193 $9,293 $52,650 $13,500
NSPS NNN 127 276 1,761 1,379 3,141 $363,755 685 $33,046 $171,450 $121,500
NSPS RRR 69 150 966 750 1,716 $198,719 373 $17,965 $34,500 $125,000
NESHAP BB 54 216 7,662 4,844 12,506 $1,448,441 497 $23,953 $0 $0
NESHAP Y 4 8.08 60 9 69 $7,847 9 $444 $0 $0
NESHAP V 67 134 4,700 4,418 9,118 $1,056,077 308 $14,860 $0 $0
NESHAP F, G, H, and I 185 1,145 659,721 108,813 768,534 $89,009,545 2,777 $133,902 $50,050,000 $59,800
CAR d 45 225 197,716 19,555 217,271 $25,163,745 2,289 $110,338 $12,375,000 $0
CAR Revisions e 6 6 7 0 7 $799 7 $333 $0 $0 hr/response
TOTAL f 1,356 4,239 895,000 209,000 1,100,000 $128,000,000 9,400 $450,000 $63,500,000 $485,000 259












Assumptions:









$64,000,000
a From Tables G-1 through G-13.









$192,000,000
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 11: 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 11 1 0 11
Report of seal gap excess 0.33 1 0 0.33



Subtotal 11.33
NSPS Kb
Notification of construction 19 1 0 19
Notification of actual startup 19 1 0 19
Notification of IFR internal inspection 14 1 0 14
Notification of EFR gap measurement 3.8 1 0 3.8
IFR internal inspection report 14 1 0 14
EFR 1st seal gap measurement 3.8 1 0 3.8
EFR 2nd seal gap measurement 3.8 1 0 3.8
CVS operating plan report 1.0 1 0 1.0
Report of IFR failure 34.6 1 0 34.6
Notification of IFR delay of repair/emptying 3.5 1 0 3.5
EFR 1st seal gap measurement report 413 1 0 413
EFR 2nd seal gap measurement report 413 1 0 413
Notification of refill 385 1 0 385



Subtotal 1,328
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 170 2 0 340



Subtotal 340
NSPS VVa
Initial performance test report 5 1 0 5
Repeat performance test report 1 1 0 1
Notification of construction 3 1 0 3
Notification of reconstruction/modification 2 1 0 2
Notification of actual startup 5 1 0 5
Notification of initial/repeat performance test 6 1 0 6
Semiannual report 65 2 0 130



Subtotal 152
NSPS DDD
Initial performance test report 5 1 0 5
Repeat performance test report 1 1 0 1
Notification of construction/modification 5 1 0 5
Notification of actual startup 5 1 0 5
Notification of initial/repeat performance test 6 1 0 6
Semiannual report 73 2 0 146



Subtotal 168
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 38 2 0 76



Subtotal 80.4
NSPS NNN
Initial performance test report 9 1 0 9
Repeat performance test report 1.8 1 0 1.8
Notification of construction/modification 9 1 0 9
Notification of actual startup 9 1 0 9
Notification of initial/repeat performance test 10.8 1 0 10.8
Semiannual report 118 2 0 236



Subtotal 276
NSPS RRR
Initial performance test report 5 1 0 5
Repeat performance test report 1 1 0 1
Notification of construction/modification 5 1 0 5
Notification of actual startup 5 1 0 5
Notification of initial/repeat performance test 6 1 0 6
Semiannual report 64 2 0 128



Subtotal 150
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 0.08 1 0 0.08
Quarterly emission report 0 4 0 0



Subtotal 8.08
NESHAP V
Initial performance test report 0 1 0 0
Reference method 21/22 test 0 1 0 0
Repeat performance test report 0 1 0 0
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 initial/repeat performance test 0 1 0 0
Application for alternative 0 1 0 0
Initial report 0 1 0 0
Semiannual report 67 2 0 134



Subtotal 134
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) 180 5 0 900



Subtotal 1,145
CAR Provisions
Complete forms (see Table 6) 45 5 0 225



Subtotal 225
CAR Direct Final Standards
Write report (see Table 7) 6 1 0 6



Subtotal 6

Total responses (all subparts) 4,239

Sheet 12: Table F-1

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












$49.44 $66.62 $26.75
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) b
Report review: New plant


0


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 11 5.5 0.28 0.55 $304.95
Report of gap excesses d, e 1 1 1 0.33 0.33 0.02 0.03 $18.30
TOTAL (rounded) f



6.7 $320









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 10 existing sources with an average of 50 tanks per facility.
b This ICR uses the following labor rates: $66.62 for managerial, $49.44 for technical, and $26.75 for clerical labor. These rates are from the Office of Personnel Management (OPM), 2019 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 (1) will use a vapor recovery control system and 90 percent of respondents (9) 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 (9) will perform a secondary seal gap measurement. Twenty percent of respondents (2) will conduct a primary seal gap measurement. Total respondents submitting a notification of either primary or secondary gap measurement: 9 + 2 = 11.
e Assume that 3 percent of respondents submitting a notification of either primary or secondary gap measurement (11) will have excessive seal gaps (primary or secondary) requiring that a single report be filed once every three years. (11 x 0.03 = 0.33)
f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

Sheet 13: Table F-2

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












$49.44 $66.62 $26.75
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) b
Report review: New plant






Notification of construction 2 1 2 19 38 1.9 3.8 $2,106.95
Notification of anticipated startup 1 1 1 19 19 0.95 1.9 $1,053.47
Notification of actual startup 1 1 1 19 19 0.95 1.9 $1,053.47
Notification of initial inspection 1 1 1 19 19 0.95 1.9 $1,053.47
Report review: New and Existing plants






IFR failure report c 1 1 1 35 34.6 1.73 3.46 $1,918.43
Notification of IFR delay of repair/emptying d 1.2 1 1.2 3.5 4.2 0.21 0.4 $230.21
Notification of refill e 1 1 1 385 385 19.2 38.5 $21,323.28
TOTAL (rounded) f



600 $28,700









Assumptions:







a We estimate an average of 413 existing respondents with an average of 4,667 regulated vessels in service will be subject over the next three years. We also estimate 75 percent (3,500) of vessels have an internal floating roof (IFR), 20 percent (933) have an external floating roof (EFR), and 5 percent (233) have a closed vent system (CVS). We estimate 19 new respondents per year will become subject to subpart Kb, and assume a distribution similar to that of existing respondents; therefore, 14 new respondents have an IFR, 4 have an ERF, and 1 has 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: $66.62 for managerial, $49.44 for technical, and $26.75 for clerical labor. These rates are from the Office of Personnel Management (OPM), 2019 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 estimate that 80% of existing and new respondents ((413+19) x 0.8 = 346) will choose visual inspections. We estimate 10 percent failure rate for the 346 respondents choosing annual visual inspections, yielding 35 reports. (346 x 0.1 = 35 (rounded)).
d Estimate 10 percent of failed IFRs either are delayed in repair or are emptied, yielding 3.5 notifications per year.
e Assume all 3,500 existing 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 350 per year. This number was added to the estimated 35 visual inspection failures that would lead to internal inspections, for a total estimate of 385 notifications of refill.
f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

Sheet 14: Table F-3

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












$49.44 $66.62 $26.75
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) 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 4 170 680 34 68 $37,703.28
TOTAL (rounded) c



780 $37,700









Assumptions:







a All new sources are subject to subpart VVa. There are an average of 170 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: $66.62 for managerial, $49.44 for technical, and $26.75 for clerical labor. These rates are from the Office of Personnel Management (OPM), 2019 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 15: Table F-4

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












$49.44 $66.62 $26.75
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) b
Report review: New plant






Notification of construction c 8 1 8 3 24 1.2 2.4 $1,330.70
Notification of reconstruction/ modification c 2 1 2 2 4 0.2 0.4 $221.78
Notification of actual startup 0.5 1 0.5 5 2.5 0.13 0.25 $138.62
Notification of initial/repeat test d 0.5 1 0.5 6 3 0.15 0.3 $166.34
Review test results d 2 1 2 6 12 0.6 1.2 $665.35
Report review: Existing plant







Semiannual emission report 2.45 2 4.9 65 319 15.9 31.9 $17,659.55
TOTAL (rounded) e



420 $20,000









Assumptions:







a Assume there will be an average of 5 new, modified, or reconstructed facilities each year and an average of 65 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: $66.62 for managerial, $49.44 for technical, and $26.75 for clerical labor. These rates are from the Office of Personnel Management (OPM), 2019 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 3 new sources will be new due to construction while 2 new sources will be new 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 16: Table F-5

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












$49.44 $66.62 $26.75
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) b
Report review: New plant






Notification of construction/ modification 2 1 2 5 10 0.5 1 $554.46
Notification of actual startup 2 1 2 5 10 0.5 1 $554.46
Initial performance test 8 1 8 5 40 2 4 $2,217.84
Repeat performance test c 8 1 8 1 8 0.4 0.8 $443.57
Report review: Existing plant







Semiannual report 2 2 4 73 292 14.6 29.2 $16,190.23
TOTAL (rounded) d



414 $20,000









Assumptions:







a We assume 5 new affected sources per year and an average of 73 existing affected sources over the next three years.
b This ICR uses the following labor rates: $66.62 for managerial, $49.44 for technical, and $26.75 for clerical labor. These rates are from the Office of Personnel Management (OPM), 2019 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-6

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












$49.44 $66.62 $26.75
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) b
Report review: New plant






Notification of construction/ modification 2 1 2 1 2 0.1 0.2 $110.89
Notification of anticipated startup 2 1 2 1 2 0.1 0.2 $110.89
Notification of actual startup 2 1 2 1 2 0.1 0.2 $110.89
Initial performance test 8 1 8 1 8 0.4 0.8 $443.57
Repeat performance test c 8 1 8 0.2 1.6 0.1 0.2 $88.71
Report review: Existing plant







Semiannual report 2 2 4 38 152 7.6 15.2 $8,427.79
TOTAL (rounded) d



193 $9,290









Assumptions:







a Assume 1 new affected source per year and an average of 38 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: $66.62 for managerial, $49.44 for technical, and $26.75 for clerical labor. These rates are from the Office of Personnel Management (OPM), 2019 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-7

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












$49.44 $66.62 $26.75
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) b
Report review: New plant






Notification of construction/ modification 2 1 2 9 18 0.9 1.8 $998.03
Notification of actual startup 2 1 2 9 18 0.9 1.8 $998.03
Initial performance test 8 1 8 9 72 3.6 7.2 $3,992.11
Repeat performance test c 8 1 8 2 16 0.8 1.6 $887.14
Report review: Existing plant







Semiannual report 2 2 4 118 472 23.6 47.2 $26,170.51
TOTAL (rounded) d



700 $33,000









Assumptions:







a Assume 9 new affected sources per year subject to subpart NNN and not the HON. We assume 118 existing affected sources over the next three years subject to subpart NNN and not the HON. 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: $66.62 for managerial, $49.44 for technical, and $26.75 for clerical labor. These rates are from the Office of Personnel Management (OPM), 2019 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 19: Table F-8

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












$49.44 $66.62 $26.75
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) b
Report review: New plant






Notification of construction/ modification 2 1 2 5 10 0.5 1 $554.46
Notification of actual startup 2 1 2 5 10 0.5 1 $554.46
Initial performance test 8 1 8 5 40 2 4 $2,217.84
Repeat performance test c 8 1 8 1 8 0.4 0.8 $443.57
Report review: Existing plant







Semiannual report 2 2 4 64 256 12.8 25.6 $14,194.18
TOTAL (rounded) d



370 $18,000









Assumptions:







a Assume 5 new affected sources per year subject to subpart RRR and not the HON. Assume 64 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: $66.62 for managerial, $49.44 for technical, and $26.75 for clerical labor. These rates are from the Office of Personnel Management (OPM), 2019 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 20: Table F-9

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












$49.44 $66.62 $26.75
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) 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 $23,952.67
TOTAL (rounded) c



497 $24,000









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: $66.62 for managerial, $49.44 for technical, and $26.75 for clerical labor. These rates are from the Office of Personnel Management (OPM), 2019 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 21: Table F-10

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












$49.44 $66.62 $26.75
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) 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 $443.57
Supplemental delay report d 1 1 1 0 0 0 0 $0
Quarterly emission report e N/A






TOTAL (rounded) f



9 $444









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: $66.62 for managerial, $49.44 for technical, and $26.75 for clerical labor. These rates are from the Office of Personnel Management (OPM), 2019 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 22: Table F-11

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












$49.44 $66.62 $26.75
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) b
Report review: New plant






Notification of construction 2 1 2 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
Initial performance test 8 1 8 0 0 0 0 $0
Repeat performance test c 8 1 8 0 0 0 0 $0
Semiannual report 2 2 4 67 268 13.4 26.8 $14,859.53
TOTAL (rounded) d



308 $14,900









Assumptions:







a Assume no new sources per year and 67 existing sources subject to Subpart V, but not the HON.
b This ICR uses the following labor rates: $66.62 for managerial, $49.44 for technical, and $26.75 for clerical labor. These rates are from the Office of Personnel Management (OPM), 2019 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 23: Table F-12

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









$49.44 $66.62 $26.75

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 ($) a
Report review:





1. Initial 2 5 10 0.5 1 $554.46
2. Implementation plan or permit 20 5 100 5 10 $5,544.60
3. Compliance status 40 5 200 10 20 $11,089.20
4. Review equipment leak monitoring b 7 135 945 47 95 $52,396.47
5. Notification of construction/reconstruction 2 5 10 0.5 1 $554.46
6. Notification of anticipated startup 2 5 10 0.5 1 $554.46
7. Notification of actual startup 2 5 10 0.5 1 $554.46
8. Notification of performance test 2 5 10 0.5 1 $554.46
9. Review of test results 8 5 40 2 4 $2,217.84
10. Review periodic reports c 4 270 1,080 54 108 $59,881.68
TOTAL (rounded)

2,780 $134,000








Assumptions:






a This ICR uses the following labor rates: $66.62 for managerial, $49.44 for technical, and $26.75 for clerical labor. These rates are from the Office of Personnel Management (OPM), 2019 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 There are 135 existing sources out of the 180 total that will continue to comply with the HON.
c The 135 existing sources complying with the HON file semi-annual reports.

Sheet 24: Table G-1

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












$120.27 $141.06 $58.67
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) b
1. Applications N/A






2. Survey and Studies N/A






3. Reporting requirements







A. Familiarize with regulatory requirements c 1 1 1 10 10 0.5 1 $1,331.90
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 9 9 0.45 0.9 $1,198.71
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 11 16.5 0.8 1.7 $2,197.64
Report of seal gap excess e 2.5 1 2.5 0.33 0.8 0.04 0.1 $109.88
Information on vapor recovery See 3B






Subtotal for Reporting Requirements



42 $4,838
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 9 2,250 112.5 225 $299,677.50
Primary seal gap measurements d, e, g 2 10 20 2 40 2 4 $5,327.60
Fill/refill record h, i 0.2 10 2 2 4 0.2 0.4 $532.76
Subtotal for Recordkeeping Requirements



2,638 $305,538
TOTAL LABOR BURDEN AND COST (rounded) j



2,680 $310,000
TOTAL CAPITAL AND O&M COST (rounded) j






$0
GRAND TOTAL (rounded) j






$310,000









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 10 existing sources with an average of 50 tanks per facility.
b This ICR uses the following labor rates for privately-owned sources: $141.06 for managerial, $120.27 for technical, and $58.67 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 This ICR assumes all existing respondents will have to familiarize with the regulatory requirements each year.
d Estimate that 10 percent of respondents (1) will use a vapor recovery control system and 90 percent (9) 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 (9) will perform a secondary seal gap measurement. Twenty percent (2) will conduct a primary seal gap measurement. Total respondents submitting a notification of either primary or secondary gap measurement: 9 + 2 = 11.
e Assume that 3 percent of respondents submitting a notification of either primary or secondary gap measurement (11) will have excessive seal gaps (primary or secondary) requiring that a report be filed once every three years.
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 25: Table G-2

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












$120.27 $141.06 $58.67
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) b
1. Applications N/A






2. Survey and Studies N/A






3. Reporting requirements







A. Familiarize with regulatory requirements c 1 1 1 432 432 22 43 $57,538.08
B. Required activities







One-time-only requirements







Notification of construction 2 1 2 19 38 1.9 3.8 $5,061.22
Notification of actual startup 2 1 2 19 38 1.9 3.8 $5,061.22
Notification of physical/ operational changes d N/A






Notification of malfunction d N/A






Notification of initial inspection







IFR internal inspection 2 1 2 14 29 1.4 2.9 $3,795.92
EFR gap measurement 2 1 2 4 7.6 0.38 0.8 $1,012.24
Initial inspection report







IFR internal inspection report 12 1 12 14 171 8.6 17 $22,775.49
EFR 1st seal gap measurement 12 1 12 4 46 2.3 4.6 $6,073.46
EFR 2nd seal gap measurement 8 1 8 4 30 1.5 3.0 $4,048.98
CVS operating plan report 8 1 8 1 7.6 0.38 0.76 $1,012.24
Repeat requirements







Internal IFR inspection e 12 1 12 83 991 50 99 $132,017.93
Visual IFR inspection e 8 1 8 330 2,643 132 264 $352,047.81
Report of IFR failure e, f 2 1 2 35 69.2 3.46 7 $9,216.75
Notification of IFR delay of repair/emptying e, f, g 4 1 4 3.5 13.84 0.692 1.384 $1,843.35
EFR 1st seal gap measurement report 12 1 12 413 4,956 247.8 495.6 $660,089.64
EFR 2nd seal gap measurement report 8 1 8 413 3,304 165.2 330.4 $440,059.76
Notification of refill h 2 1 2 385 769 38 76.9235 $102,454.41
Subtotal for Reporting Requirements



15,577 $1,804,108
4. Recordkeeping requirements







A. Familiarize with regulatory requirements c See 3A






B. Gather and record information







Vessel volumes, liquid vapor pressures, flares 8 1 8 413 3,304 165.2 330.4 $440,059.76
113b(a) inspection 12 1 12 413 4,956 247.8 495.6 $660,089.64
113b(b) gap measurement 12 1 12 413 4,956 247.8 495.6 $660,089.64
C. Develop record system N/A






D. Time to enter information







CVS parameter records 2 52 104 234 24,367 1,218 2,437 $3,245,398.11
E. Train personnel N/A






F. Audits N/A






Subtotal for Recordkeeping Requirements



43,220 $5,005,637
TOTAL LABOR BURDEN AND COST (rounded) i



58,800 $6,810,000
TOTAL CAPITAL AND O&M COST (rounded) i






$330,000
GRAND TOTAL (rounded) i






$7,140,000









Assumptions:







a We estimate an average of 413 existing respondents with an average of 4,667 regulated vessels in service will be subject over the next three years. We also estimate 75 percent (3,500) of vessels have an internal floating roof (IFR), 20 percent (933) have an external floating roof (EFR), and 5 percent (233) have a closed vent system (CVS). We estimate 19 new respondents per year will become subject to subpart Kb, and assume a distribution similar to that of existing respondents; therefore, 14 new respondents have an IFR, 4 have an ERF, and 1 has 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 for privately-owned sources: $141.06 for managerial, $120.27 for technical, and $58.67 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 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 3,500 IFRs associated with the 413 existing respondents, we estimate that 80 percent (413 x 0.8 = 330) will conduct an annual visual inspection, while 20 percent (413 x 0.2 = 83) 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 We estimate that 80% of existing and new respondents ((413+19) x 0.8 = 346) will choose visual inspections. We estimate 10 percent failure rate for the 346 respondents choosing annual visual inspections, yielding 35 reports. (346 x 0.1 = 35 (rounded)).
g Estimate 10 percent of the 35 failed IFRs either are delayed in repair or are emptied, yielding 3.5 notifications per year.
h Assume all 3,500 existing 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 350 per year. This number was added to the estimated 35 visual inspection failures that would lead to internal inspections, for a total estimate of 385 notifications of refill.
i Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

Sheet 26: Table G-3

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












$120.27 $141.06 $58.67
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) b
1. Applications N/A






2. Survey and Studies N/A






3. Reporting requirements







A. Familiarize with regulatory requirements c 1 1 1 170 170 8.5 17 $22,642.30
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 8 170 1,360 68 136 $181,138.40
Subtotal for Reporting Requirements



1,760 $203,781
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 80 170 13,600 680 1360 $1,811,384.00
F. Train personnel N/A






G. Audits N/A






Subtotal for Recordkeeping Requirements



15,640 $1,811,384
TOTAL LABOR BURDEN AND COST (rounded) e



17,400 $2,020,000
TOTAL CAPITAL AND O&M COST (rounded) e






$0
GRAND TOTAL (rounded) e






$2,020,000









Assumptions:







a All new sources are subject to Subpart VVa. There is an average of 170 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 for privately-owned sources: $141.06 for managerial, $120.27 for technical, and $58.67 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 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 27: Table G-4

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












$120.27 $141.06 $58.67
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) b
1. Applications N/A






2. Survey and Studies N/A






3. Reporting requirements







A. Familiarize with regulatory requirements c 1 1 1 70 70 3.5 7 $9,323.30
B. Required activities







Initial performance test report 48 1 48 5 240 12 24 $31,965.60
Repeat performance test report d 48 1 48 1 48 2.4 4.8 $6,393.12
C. Create information See 3B






D. Gather existing information See 3E






E. Write report







Notification of construction e 2 1 2 3 6 0.3 0.6 $799.14
Notification of reconstruction/modification e 2 1 2 2 4 0.2 0.4 $532.76
Notification of actual startup 2 1 2 5 10 0.5 1.0 $1,331.90
Notification of initial/repeat performance test d 2 1 2 6 12 0.6 1.2 $1,598.28
Semiannual report 4.5 2 9 65 585 29 59 $77,916.15
Subpart for Reporting Requirements



1,121 $129,860
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 58 5,191 260 519 $691,389.29
Records of operating parameters - small facilities f 95.2 1 95.2 7 618.8 31 62 $82,417.97
F. Train personnel N/A






G. Audits N/A






Subtotal for Recordkeeping Requirements



6,681 $773,807
TOTAL LABOR BURDEN AND COST (rounded) g



7,800 $904,000
TOTAL CAPITAL AND O&M COST (rounded) g






$1,400
GRAND TOTAL (rounded) g






$905,000









Assumptions:







a Assume there will be an average of 5 new, modified, or reconstructed facilities each year and an average of 65 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 for privately-owned sources: $141.06 for managerial, $120.27 for technical, and $58.67 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 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 3 new sources will be new due to construction while 2 new sources will be new 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 28: Table G-5

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












$120.27 $141.06 $58.67
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) b
1. Applications N/A






2. Survey and Studies N/A






3. Reporting requirements







A. Familiarize with regulatory requirements c 1 1 1 78 78 3.9 7.8 $10,388.82
B. Required activities







Initial performance test report 360 1 360 5 1,800 90 180 $239,742.00
Repeat performance test report d 360 1 360 1 360 18 36 $47,948.40
C. Write report







Notification of construction/modification 2 1 2 5 10 0.5 1 $1,331.90
Notification of actual startup 1 1 1 5 5 0.3 0.5 $665.95
Notification of initial/repeat performance test 2 1 2 6 12 0.6 1.2 $1,598.28
Semiannual report 3 2 6 73 438 22 44 $58,337.22
Subtotal for Reporting Requirements



3,108 $360,013
4. Recordkeeping requirements







Records of operating parameters for control devices 1 12 12 5 60 3 6 $7,991.40
Records of operating conditions exceeding last performance test 1 8 8 73 584 29 58 $77,782.96
Records of startup, shutdown, malfunction, etc. 0.25 5 1.25 73 91 4.6 9.1 $12,153.59
Subtotal for Recordkeeping Requirements



846 $97,928
TOTAL LABOR BURDEN AND COST (rounded) e



3,950 $458,000
TOTAL CAPITAL AND O&M COST (rounded) e






$696,000
GRAND TOTAL (rounded) e






$1,150,000









Assumptions:







a Assume 5 new affected sources per year and an average of 73 existing affected sources over the next three years.
b This ICR uses the following labor rates for privately-owned sources: $141.06 for managerial, $120.27 for technical, and $58.67 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 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-6

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












$120.27 $141.06 $58.67
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) b
1. Applications N/A






2. Survey and Studies N/A






3. Reporting requirements







A. Familiarize with regulatory requirements c 1 1 1 39 39 1.95 3.9 $5,194.41
B. Required activities







Initial performance test report 60 1 60 1 60 3 6 $7,991.40
Repeat performance test report d 60 1 60 0.2 12 0.6 1.2 $1,598.28
C. Write report







Notification of construction/modification 2 1 2 1 2 0.1 0.2 $266.38
Notification of actual startup 1 1 1 1 1 0.05 0.1 $133.19
Notification of initial/repeat performance test 2 1 2 1.2 2.4 0.1 0.2 $319.66
Semiannual report 3 2 6 38 228 11 23 $30,367.32
Subtotal for Reporting Requirements



396 $45,871
4. Recordkeeping requirements







Records of operating parameters for control devices 1 12 12 1 12 0.6 1.2 $1,598.28
Records of operating conditions exceeding last performance test 1 8 8 38 304 15 30 $40,489.76
Records of startup, shutdown, malfunction, etc. 0.25 5 1.25 38 48 2.4 4.8 $6,326.53
Subtotal for Recordkeeping Requirements



418 $48,415
TOTAL LABOR BURDEN AND COST (rounded) e



814 $94,300
TOTAL CAPITAL AND O&M COST (rounded) e






$66,200
GRAND TOTAL (rounded) e






$161,000









Assumptions:







a Assume 1 new affected source per year and an average of 38 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 for privately-owned sources: $141.06 for managerial, $120.27 for technical, and $58.67 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 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-7

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












$120.27 $141.06 $58.67
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) b
1. Applications N/A






2. Survey and Studies N/A






3. Reporting requirements







A. Familiarize with regulatory requirements c 1 1 1 127 127 6.4 13 $16,915.13
B. Required activities







Initial performance test report 60 1 60 9 540 27 54 $71,922.60
Repeat performance test report d 60 1 60 2 108 5.4 11 $14,384.52
C. Write report







Notification of construction/modification 2 1 2 9 18 0.9 1.8 $2,397.42
Notification of actual startup 1 1 1 9 9 0.45 0.9 $1,198.71
Notification of initial/repeat performance test 2 1 2 11 22 1.1 2.2 $2,876.90
Semiannual report 3 2 6 118 708 35 71 $94,298.52
Subtotal for Reporting Requirements



1,761 $203,994
4. Recordkeeping requirements







Records of operating parameters for control devices 1 12 12 9 108 5.4 11 $14,384.52
Records of operating conditions exceeding last performance test 1 8 8 118 944 47 94 $125,731.36
Records of startup, shutdown, malfunction, etc. 0.25 5 1.25 118 148 7.4 15 $19,645.53
Subtotal for Recordkeeping Requirements



1,379 $159,761
TOTAL LABOR BURDEN AND COST (rounded) e



3,140 $364,000
TOTAL CAPITAL AND O&M COST (rounded) e






$293,000
GRAND TOTAL (rounded) e






$657,000









Assumptions:







a Assume 9 new affected sources per year subject to subpart NNN and not the HON, and 118 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 for privately-owned sources: $141.06 for managerial, $120.27 for technical, and $58.67 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 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 31: Table G-8

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












$120.27 $141.06 $58.67
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) b
1. Applications N/A






2. Survey and Studies N/A






3. Reporting requirements







A. Familiarize with regulatory requirements c 1 1 1 69 69 3.45 6.9 $9,190.11
B. Required activities







Initial performance test report 60 1 60 5 300 15 30 $39,957.00
Repeat performance test report d 60 1 60 1 60 3 6 $7,991.40
C. Write report







Notification of construction/modification 2 1 2 5 10 0.5 1 $1,331.90
Notification of actual startup 1 1 1 5 5 0.25 0.5 $665.95
Notification of initial/repeat performance test 2 1 2 6 12 0.6 1.2 $1,598.28
Semiannual report 3 2 6 64 384 19 38 $51,144.96
Subtotal for Reporting Requirements



966 $111,880
4. Recordkeeping requirements







Records of operating parameters for control devices 1 12 12 5 60 3 6 $7,991.40
Records of operating conditions exceeding last performance test 1 8 8 64 512 26 51 $68,193.28
Records of startup, shutdown, malfunction, etc. 0.25 5 1.25 64 80 4 8 $10,655.20
Subtotal for Recordkeeping Requirements



750 $86,840
TOTAL LABOR BURDEN AND COST (rounded) e



1,720 $199,000
TOTAL CAPITAL AND O&M COST (rounded) e






$160,000
GRAND TOTAL (rounded) e






$359,000









Assumptions:







a Assume 5 new affected sources per year subject to subpart RRR and not the HON, and 64 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 for privately-owned sources: $141.06 for managerial, $120.27 for technical, and $58.67 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 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 32: Table G-9

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












$120.27 $141.06 $58.67
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) 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 $7,192
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 $4,395.27
Marine vessels 80 1 80 66 5,280 264 528 $703,243.20
Closed vent leak inspection 8 1 8 54 432 21.6 43.2 $57,538.08
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 $115,076.16
Subtotal for Reporting Requirements



7,662 $887,445
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 $560,996.28
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 $560,996
TOTAL LABOR BURDEN AND COST (rounded) e



12,500 $1,450,000
TOTAL CAPITAL AND O&M COST (rounded) e






$0
GRAND TOTAL (rounded) e






$1,450,000









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 for privately-owned sources: $141.06 for managerial, $120.27 for technical, and $58.67 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 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 33: Table G-10

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












$120.27 $141.06 $58.67
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) 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 $532.76
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 $4,262.08
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 $2,131.04
Supplemental delay report e 2 1 2 0.1 0.2 0.01 0.02 $21.31
Quarterly emission report f None expected






Subtotal for Reporting Requirements



60 $6,947
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 $1,065.52
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 LABOR BURDEN AND COST (rounded) g



69 $7,850
TOTAL CAPITAL AND O&M COST (rounded) g






$0
GRAND TOTAL (rounded) g






$7,850









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 for privately-owned sources: $141.06 for managerial, $120.27 for technical, and $58.67 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 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 34: Table G-11

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












$120.27 $141.06 $58.67
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) 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 3.4 6.7 $8,923.73
B. Required activities







Initial performance test 20 1 20 0 0 0 0 $0
Reference method 21/22 test 4 1 4 0 0 0 0 $0
Repeat performance test d 20 1 20 0 0 0 0 $0
C. Create information See 3B






D. Gather existing information See 3B






E. Write report







Notification of construction/reconstruction 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 initial/repeat performance test d 2 1 2 0 0 0.0 0.0 $0
Report of performance test See 3B






Application for alternative 10 1 10 0 0 0 0 $0
Initial report 8 1 8 0 0 0 0 $0
Semiannual report 30 2 60 67 4,020 201 402 $535,423.80
Subtotal for Reporting Requirements



4,700 $544,348
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. e 1.5 1 1.5 2 3 0.2 0.3 $399.57
Record of operation, parameters, and emissions 0.1 365 36.5 67 2,446 122 245 $325,716.15
Record of leaks detected 0.4 52 20.8 67 1,394 70 139 $185,613.58
F. Train personnel N/A






G. Audits N/A






Subtotal for Recordkeeping Requirements



4,418 $511,729
TOTAL LABOR BURDEN AND COST (rounded) e



9,120 $1,056,000
TOTAL CAPITAL AND O&M COST (rounded) e






$0
GRAND TOTAL (rounded) e






$1,056,000









Assumptions:







a Assume 0 new sources per year and 67 existing sources subject to subpart V, but not the HON.
b This ICR uses the following labor rates for privately-owned sources: $141.06 for managerial, $120.27 for technical, and $58.67 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 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 Assume 3% of sources experience a startup, shutdown, or malfunction per year.
f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

Sheet 35: Table G-12

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












$120.27 $141.06 $58.67
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Average hours per activity a Number of activities per year per respondent Technical hours per year per respondent Estimated number of New Respondents b Estimated technical hours per year
(E=CxD)
Estimated managerial hours per year
(F=Ex0.05)
Estimated clerical hours per year
(G=Ex0.1)
Total cost per year ($) c
1. Familiarize with regulatory requirements 2.69 93 250 5 1,250 63 125 $166,487.50
2. Plan activities 3.82 93 355 5 1,775 89 178 $236,412.25
3. Training 3.47 38 132 5 660 33 66 $87,905.40
4. Creation, testing, research, and development 2.4 1,778 4,266 5 21,330 1,067 2,133 $2,840,942.70
5. Gather information, monitor/inspect 1.4 2,102 2,943 5 14,715 736 1,472 $1,959,890.85
6. Process/compile and review 0.8 50 40 5 200 10 20 $26,638.00
7. Complete reports 11.37 49 557 5 2,785 139 279 $370,934.15
8. Record/disclose 9.98 49 489 5 2,445 122 245 $325,649.55
9. Store/file 5.18 51 264 5 1,320 66 132 $175,810.80
TOTAL LABOR BURDEN AND COST (rounded) d



53,500 $6,190,000
TOTAL CAPITAL AND O&M COST (rounded) d






See Table G-13
GRAND TOTAL (rounded) d






$6,190,000









Assumptions:







a Average hours per activity are back-calculated by dividing (C) by (B).







b The number of new respondents (5) is from a previously approved ICR.







c This ICR uses the following labor rates for privately-owned sources: $141.06 for managerial, $120.27 for technical, and $58.67 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.
d 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 36: Table G-13

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














$120.27 $141.06 $58.67


Burden item (A) (B) (C) (D) (E) (F) (G) (H)

Average hours per activity a Number of activities per year per respondent a Technical hours per year per respondent a, b Technical hours per year per respondent for wastewater a, c Estimated technical hours per year
(E=Cx180+Dx45)
Estimated managerial hours per year
(F=Ex0.05)
Estimated clerical hours per year
(G=Ex0.1)
Total cost per year ($) d

1. Familiarize with regulatory requirements 3.61 23 69 14 9,945 497 995 $1,324,574.55

2. Plan activities 6.08 13 61 18 9,045 452 905 $1,204,703.55

3. Training 5.25 4 17 4 2,475 124 248 $329,645.25

4. Creation, testing, research, and development 17.85 99 1,617 150 225,045 11,252 22,505 $29,973,743.55

5. Gather information, monitor/inspect 2.5 677 1,693 0 228,555 11,428 22,856 $30,441,240.45

6. Process/compile and review 20 1 20 0 2,700 135 270 $359,613.00

7. Complete reports 81.2 5 388 18 53,190 2,660 5,319 $7,084,376.10

8. Record/disclose 17.46 26 442 12 60,210 3,011 6,021 $8,019,369.90

9. Store/file 6.77 35 222 15 30,645 1,532 3,065 $4,081,607.55

TOTAL LABOR BURDEN AND COST (rounded) e



720,000 $82,800,000

TOTAL CAPITAL AND O&M COST (rounded) e






$50,100,000

GRAND TOTAL (rounded) e






$133,000,000












Assumptions:









a Average Hours per Activity (A) is back-calculated: (A) = ((C) + (D))/(B).

b There are 135 existing sources out of the 180 total that will continue to comply with the HON.
45
c The 45 facilities complying with the CAR will still be required to comply with HON requirements for wastewater.

d This ICR uses the following labor rates for privately-owned sources: $141.06 for managerial, $120.27 for technical, and $58.67 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.

e 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 37: 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 10 $0
Subtotal $0
NSPS Kb a $13,500 1 $13,500 $1,350 234 $316,366 For capital, these are tanks with CVS as control. Revised from 19 to 1.
Subtotal $330,000 For O&M, these are the 5% of existing and new tanks using CVS as control. Revised from 413 to 234.
NSPS VV $0 0 $0 $0 170 $0
Subtotal $0
NSPS Vva b $1,400 1 $1,400 $0 65 $0 Revised from 5 to 1. Only 15% of new sources purchase monitoring equipment.
Subtotal $1,400
NSPS DDD $30,000 5 $150,000 $7,000 78 $546,000 Revised from 73 to 78
Subtotal $696,000
NSPS III $13,500 1 $13,500 $1,350 39 $52,650 Revised from 38 to 39
Subtotal $66,200
NSPS NNN $13,500 9 $121,500 $1,350 127 $171,450 Revised from 118 to 127
Subtotal $293,000
NSPS RRR $25,000 5 $125,000 $500 69 $34,500 Revised from 64 to 69
Subtotal $160,000
NESHAP BB $0 0 $0 $0 54 $0
Subtotal $0
NESHAP Y $0 0 $0 $0 4 $0
Subtotal $0
NESHAP V $0 0 $0 $0 67 $0
Subtotal $0
NESHAP F $0 0 $0 $0 0 $0
Subtotal $0
NESHAP G $25,000 2 $50,000 $275,000 182 $50,050,000 Revised from 180 to 182
Subtotal $50,100,000
NESHAP H c $1,400 3 $9,800 $0 0 $0
Subtotal $9,800
NESHAP I $0 0 $0 $0 0 $0
Subtotal $0
CAR $0 0 $0 $275,000 45 $12,375,000
Subtotal $12,400,000
CAR Revisions $0 0 $0 $0 6 $0
Subtotal $0
Total for CAR and Referencing Subparts $64,000,000








a We assume that 5% of the 19 new respondents use a CVS as control, and that 5% of all existing storage tanks use a CVS as control. (413 existing respondents x 11.3 tanks per respondent x 5% tanks with CVS = 233)
b We assume that 5 new process units are subject to NSPS Subpart VVa each year, and that 15 percent of all new sources are area sources, and that only area sources that construct new process units might purchase a monitoring instrument. (5 new respondents x 15% = 1 (rounded))
c We estimate that 80 percent of new facilities contract out LDAR services, and 20 percent perform in-house. The 2 facilities (rounded) which contract out will purchase one unit as backup. The 1 remaining facility (rounded) performing LDAR in-house will purchase 5 units to support the program. The total annual capital/startup cost is 7 units x $1,400 = $9,800.

Sheet 38: Labor

Labor Rates




Private
Technical Managerial Clerical
$120.27 $141.06 $58.67
b This ICR uses the following labor rates for privately-owned sources: $141.06 for managerial, $120.27 for technical, and $58.67 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.



Agency
Technical Managerial Clerical
$49.44 $66.62 $26.75
b This ICR uses the following labor rates: $66.62 for managerial, $49.44 for technical, and $26.75 for clerical labor. These rates are from the Office of Personnel Management (OPM), 2019 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.
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