Burden Calculations Table

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Overview

Table 1.1
Table 1.2
Table 1.3
Table 1.4
Table 1.5
Table 1.6 Total
Table 2
Summary Table
Tot Ann Resp
O&M (Bulk Terminals Only)

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Sheet 1: Table 1.1

Table 1.1: Annual Respondent Burden and Cost – NESHAP for Source Categories: Gasoline Distribution Bulk Terminals, Bulk Plants, Pipeline Facilities, and Gasoline Dispensing Facilities (40 CFR Part 63, Subparts BBBBBB and CCCCCC) (Renewal)
			September 2020:		122.66	149.84	60.88
Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical person- hours per year (E=CxD)	(F) Management person hours per year (Ex0.05)	(G) Clerical person hours per year (Ex0.1)	(H) Total Cost per year b
1.1 Bulk Terminals
(a) Familiarization with rule requirements	6	1	6	1,100	6,600	330	660	$899,184
(b) Prepare Initial Notification c	4	0	4	0	0	0	0	$0
(c) Perform Initial Performance Test c	175	0	175	0	0	0	0	$0
(d) Prepare Notification of Compliance Status c	4	0	4	0	0	0	0	$0
(e) Perform annual storage tank inspection d	12	1	12	1,100	13,200	660	1,320	$1,798,368
(f) Perform equipment leak inspections d	2	12	24	1,100	26,400	1,320	2,640	$3,596,736
(g) Keep records of performance tests, storage tank and equipment leak inspections, and cargo tank vapor tightness documentation	0.75	12	9	1,100	9,900	495	990	$1,348,776
(h) Submit semiannual compliance report	4	2	8	1,100	8,800	440	880	$1,198,912
Subtotal Reporting [(h)]					10,120			$1,198,912
Subtotal Recordkeeping [(e) - (g)]					64,515			$7,643,064
TOTAL LABOR BURDEN AND COST (rounded)e					74,600			$8,840,000
TOTAL CAPITAL AND O&M COST (rounded)e								$110,000
GRAND TOTAL (rounded)e					74,600			$8,950,000
Assumptions for Table 1.1:
a We expect no new affected sources the next 3 years of this ICR. Therefore, the estimated number of respondents remains unchanged as 1,100 existing bulk terminals.
b This ICR uses the following labor rates: $149.84 per hour for Executive, Administrative, and Managerial labor; $122.66 per hour for Technical labor, and $60.88 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2020, “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 Preparing Initial Notification, performing initial performance test, and preparing Notification of Compliance Status are one-time activities.
d Assumed that all respondents are currently performing annual storage tank inspections; and, that all are currently performing equipment leak inspections at least once per month.
e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 2: Table 1.2

Table 1.2: Annual Respondent Burden and Cost – NESHAP for Source Categories: Gasoline Distribution Bulk Terminals, Bulk Plants, Pipeline Facilities, and Gasoline Dispensing Facilities (40 CFR Part 63, Subparts BBBBBB and CCCCCC) (Renewal)
			September 2020:		122.66	149.84	60.88
Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical person- hours per year (E=CxD)	(F) Management person hours per year (Ex0.05)	(G) Clerical person hours per year (Ex0.1)	(H) Total Cost per year b
1.2 Pipeline Breakout Stations
(a) Familiarization with rule requirements	6	1	6	460	2,760	138	276	$376,022.40
(b) Prepare Initial Notificationc	8	1	8	0	0	0	0	$0
(c) Prepare Notification of Compliance Statusc	8	1	8	0	0	0	0	$0
(d) Perform annual storage tank inspectiond	12	1	12	460	5,520	276	552	$752,044.80
(e) Perform equipment leak inspectionsd	2	12	24	460	11,040	552	1,104	$1,504,089.60
(f) Keep records of storage tank and equipment leak inspectionsd	16	1	16	460	7,360	368	736	$1,002,726.40
(g) Submit semiannual compliance report	4	2	8	460	3,680	184	368	$501,363.20
Subtotal Reporting [(g)]					4,232			$501,363
Subtotal Recordkeeping [(d) - (f)]					30,682			$3,634,883
TOTAL LABOR BURDEN AND COST (rounded)e					34,900			$4,140,000
TOTAL CAPITAL AND O&M COST (rounded)e								$0
GRAND TOTAL (rounded)e					34,900			$4,140,000
Assumptions for Table 1.2:
a We expect no new affected sources the next 3 years of this ICR. Therefore, the estimated number of respondents remains unchanged as 460 existing pipeline breakout stations.
b This ICR uses the following labor rates: $149.84 per hour for Executive, Administrative, and Managerial labor; $122.66 per hour for Technical labor, and $60.88 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2020, “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 Preparing Initial Notification, performing initial performance test, and preparing Notification of Compliance Status are one-time activities.
d Assumed that all respondents are currently performing annual storage tank inspections; and, that all are currently performing equipment leak inspections at least once per month.
e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: Table 1.3

Table 1.3: Annual Respondent Burden and Cost – NESHAP for Source Categories: Gasoline Distribution Bulk Terminals, Bulk Plants, Pipeline Facilities, and Gasoline Dispensing Facilities (40 CFR Part 63, Subparts BBBBBB and CCCCCC) (Renewal)
			September 2020:		122.66	149.84	60.88
Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical person- hours per year (E=CxD)	(F) Management person hours per year (Ex0.05)	(G) Clerical person hours per year (Ex0.1)	(H) Total Cost per year b
1.3 Pipeline Pumping Stations
(a) Familiarization with rule requirements	4	1	4	1,800	7,200	360	720	$980,928
(b) Prepare Initial Notificationc	1	1	1	0	0	0	0	$0
(c) Prepare Notification of Compliance Statusc	1	1	1	0	0	0	0	$0
(d) Perform equipment leak inspections	1	12	12	1,800	21,600	1,080	2,160	$2,942,784
(e) Keep records of equipment leak inspectionsd	0.1	12	1.2	1,800	2,160	108	216	$294,278.40
(f) Submit semiannual compliance report e	0.25	2	0.5	36	18	0.9	1.8	$2,452.32
Subtotal Reporting [(f)]					21			$2,452
Subtotal Recordkeeping [(d) - (e)]					35,604			$4,217,990
TOTAL LABOR BURDEN AND COST (rounded)f					35,600			$4,220,000
TOTAL CAPITAL AND O&M COST (rounded)f								$0
GRAND TOTAL (rounded)f					35,600			$4,220,000
Assumptions for Table 1.3:
a We expect no new affected sources the next 3 years of this ICR. Therefore, the estimated number of respondents remains unchanged as 1,800 existing pipeline pumping stations.
b This ICR uses the following labor rates: $149.84 per hour for Executive, Administrative, and Managerial labor; $122.66 per hour for Technical labor, and $60.88 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2020, “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 Preparing Initial Notification, performing initial performance test, and preparing Notification of Compliance Status are one-time activities.
d Assumed that all respondents are currently performing equipment leak inspections at least once per month.
e Assumed that, on an annual average basis, 2 percent of facilities (36) will be required to submit a semiannual compliance report because of delays in repairing equipment leaks.
f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 4: Table 1.4

Table 1.4: Annual Respondent Burden and Cost – NESHAP for Source Categories: Gasoline Distribution Bulk Terminals, Bulk Plants, Pipeline Facilities, and Gasoline Dispensing Facilities (40 CFR Part 63, Subparts BBBBBB and CCCCCC) (Renewal)
			September 2020:		122.66	149.84	60.88
Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical person- hours per year (E=CxD)	(F) Management person hours per year (Ex0.05)	(G) Clerical person hours per year (Ex0.1)	(H) Total Cost per year b
1.4 Bulk Plants
(a) Familiarization with rule requirements (in States without submerged fill rules)	Tracy Curtis: Previously 4 2	1	2	1,475	2,950	147.5	295	$401,908
(b) Familiarization with rule requirements (in States with submerged fill rules)	2	1	2	4,425	8,850	442.5	885	$1,205,724
(c) Prepare Initial Notificationc	2	1	2	0	0	0	0	$0
(d) Prepare Notification of Compliance Statusc	1	1	1	0	0	0	0	$0
(e) Perform equipment leak inspectionsd	0.25	12	3	5,900	17,700	885	1,770	$2,411,448
(f) Keep records of equipment leak inspectionsd	0.1	12	1.2	5,900	7,080	354	708	$964,579.20
(g) Submit semiannual compliance reporte	1	2	2	118	236	11.8	23.6	$32,152.64
Subtotal Reporting [(g)]					271			$32,153
Subtotal Recordkeeping [(e) - (f)]					42,067			$4,983,659
TOTAL LABOR BURDEN AND COST (rounded)f					42,300			$5,020,000
TOTAL CAPITAL AND O&M COST (rounded)f								$0
GRAND TOTAL (rounded)f					42,300			$5,020,000
Assumptions for Table 1.4:
a We expect no new affected sources the next 3 years of this ICR. Therefore, the estimated number of respondents remains unchanged as 5,900 existing bulk plants.
b This ICR uses the following labor rates: $149.84 per hour for Executive, Administrative, and Managerial labor; $122.66 per hour for Technical labor, and $60.88 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2020, “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 Preparing Initial Notification, and preparing Notification of Compliance Status are one-time activities. Note: 25% of the respondents are in States without bulk plant rules and 75% are in States with rules.
d Assumed that all respondents are currently performing equipment leak inspections at least once per month.
e Assumed that, on an annual average basis, 2 percent of facilities (118) will be required to submit a semiannual compliance report because of delays in repairing equipment leaks.
f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 5: Table 1.5

Table 1.5: Annual Respondent Burden and Cost – NESHAP for Source Categories: Gasoline Distribution Bulk Terminals, Bulk Plants, Pipeline Facilities, and Gasoline Dispensing Facilities (40 CFR Part 63, Subparts BBBBBB and CCCCCC) (Renewal)
			September 2020:		122.66	149.84	60.88
Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical person- hours per year (E=CxD)	(F) Management person hours per year (Ex0.05)	(G) Clerical person hours per year (Ex0.1)	(H) Total Cost per year b
1.5 Gasoline Dispensing Facilities
(a) Familiarization with rule requirements (facilities >100k already in compliance)	0.5	1	0.5	9,860	4,930	246.5	493	$671,663.20
(b) Familiarization with rule requirements (facilities <100k already in compliance)	0.25	0.33	0.08	0	0.0	0	0	$0
(c) Initial vapor balance system testing	6	1	6	0	0	0	0	$0
(d) Prepare Initial Notificationc	1	1	1	0	0	0	0	$0
(d) Prepare Notification of Compliance Statusc	1	1	1	0	0	0	0	$0
(e) Vapor balance system testing d	6	0.3	1.8	9,860	17,748	887.4	1,774.8	$2,417,987.52
Subtotal Reporting [(e)]					20,410			$2,417,988
Subtotal Recordkeeping [NA]					5,670			$671,663
TOTAL LABOR BURDEN AND COST (rounded)e					26,100			$3,090,000
TOTAL CAPITAL AND O&M COST (rounded)e								$0
GRAND TOTAL (rounded)e					26,100			$3,090,000
Assumptions for Table 1.5:
a We expect no new affected sources the next 3 years of this ICR. Of the total 340,000 facilities, 243,587 facilities with throughputs of <100,000 gpm that are complying with a SLT submerged fill requirement, and for the 85,340 facilities with throughputs of >100,000 gpm that are complying with a state (SLT) vapor balancing requirement, there are no other reporting or recordkeeping requirements associated with this rule for this ICR. Therefore, the estimated number of respondents with recordkeeping and reporting requirements remains unchanged from the previous ICR as 11,073 gasoline dispensing facilities, of which 9,860 install vapor balance system and 1,213 must add submerged filled as a result of this rulemaking.
b This ICR uses the following labor rates: $149.84 per hour for Executive, Administrative, and Managerial labor; $122.66 per hour for Technical labor, and $60.88 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2020, “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 Preparing Initial Notification, conducting an initial vapor balance system test, and preparing Notification of Compliance Status are one-time activities.
d Assume vapor balance pressure retesting require every three years. There are 9,860 gasoline dispensing facilities would have to retest.
e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 6: Table 1.6 Total

Table 1.6: Annual Respondent Burden and Cost – NESHAP for Source Categories: Gasoline Distribution Bulk Terminals, Bulk Plants, Pipeline Facilities, and Gasoline Dispensing Facilities (40 CFR Part 63, Subparts BBBBBB and CCCCCC) (Renewal)
Burden Item	Average Number of Respondents per year	Total person-hours per year	Total Cost per year
Subtotal for Reporting Requirements	19,120	35,054	$4,152,868
Subtotal for Recordkeeping Requirements		178,538	$21,151,260
TOTAL LABOR BURDEN AND COST		213,592	$25,304,128
TOTAL LABOR BURDEN AND COST (Rounded)a		214,000	$25,300,000
TOTAL CAPITAL AND O&M COST(Rounded)a			$110,000
GRAND TOTAL (Rounded)a			$25,400,000
a Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
		31	hr per resp

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Sheet 7: Table 2

Table 2: Average Annual EPA Burden and Cost – NESHAP for Source Categories: Gasoline Distribution Bulk Terminals, Bulk Plants, Pipeline Facilities, and Gasoline Dispensing Facilities (40 CFR Part 63, Subparts BBBBBB and CCCCCC) (Renewal)
				2021:	51.23	69.04	27.73
Activity	(A) EPA person-hours per occurrence	(B) No. of occurrences per plant per year	(C) EPA person hours per plant per year (AxB)	(D) Plants per year a	(E) Technical person-hours per year (CxD)	(F) Management person-hours per year (Ex0.05)	(G) Clerical person-hours per year (Ex0.1)	(H) Cost, $ b
Review of storage tank inspection reports	4	1	4	1,560	6,240	312	624	$358,519.20
Review semiannual compliance reports	2	2	4	1,714	6,856	342.8	685.6	$393,911.48
Review of other, non-routine reportsc	4	1	4	1,912	7,648	382.4	764.8	$439,415.84
TOTAL LABOR BURDEN AND COST (rounded)d					23,900			$1,190,000
Assumptions for Table 2:
a Number of activities per year is the sum of the number of applicable respondents from Tables 1.1 through 1.5.
b This cost is based on the following labor rates: $69.04 for Managerial, $51.23 for Technical, and $27.73 for Clerical. These rates are from the Office of Personnel Management (OPM), 2021 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 Assumed that 10 percent of affected facilities industry-wide will submit non-routine reports each year. (19,120 x 10% = 1,912)
d Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 8: Summary Table

Table 1: NESHAP for Source Categories: Gasoline Distribution Bulk Terminals, Bulk Plants, Pipeline Facilities, and Gasoline Dispensing Facilities (40 CFR Part 63, Subparts BBBBBB and CCCCCC)
	Sector	Bulk Terminals	Pipeline Breakout Stations	Pipeline Pumping Stations	Bulk Plants	Gasoline Dispensing Facilities	Total
	Burden Hours	74,600	34,900	35,600	42,300	26,100	214,000
	Labor Cost	$8,840,000	$4,140,000	$4,220,000	$5,020,000	$3,090,000	$25,300,000
	Total Cost (Labor + O&M)	$8,950,000	$4,140,000	$4,220,000	$5,020,000	$3,090,000	$25,400,000
	Number of Responses	3,410	1426	252	826	986	6,900

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Sheet 9: Tot Ann Resp

Total Annual Responses
Information Collection Activity	Number of Respondents	Number of Responses	Number of Existing…	Total
Initial Notification	19,120	0	0	0
Initial Performance Test	14,695	0	0	0
Notification of Compliance Status	14,695	0	0	0
Storage Tank Inspections (Annual Report)	1,560	1	0	1,560
Semiannual Compliance Report	1,714	2	0	3,428
Non-routine reports	1,912	1	0	1,912
			Total	6,900

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Sheet 10: O&M (Bulk Terminals Only)

Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A)	(B)	(C)	(D)	(E)	(F)	(G)
Continuous Monitoring Device	Capital/Startup Cost for One Respondent	Number of New Respondents	Total Capital/Startup Cost, (B X C)	Annual O&M Costs for One Respondent	Number of Respondents with O&M	Total O&M,
						(E X F)
CPMS for vapor processors	$0	0	$0	$1,000	110 ( 10% of Bulk Terminals)	$110,000