| Table 1a: Annual Respondent Burden and Cost - NSPS for Equipment Leaks of VOC in Petroleum Refineries (40 CFR Part 60, Subpart GGG) (Renewal) |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| Burden Item |
(A) Respondent Hours per Occurrence (Technical hours) |
(B) Number of Occurrences per Respondent per Year |
(C) Hours per Respondent per Year (C=A x B) |
(D) Number of Respondents per Year a |
(E) Technical Hours per Year (E=C x D) |
(F) Management Hours per Year (F= E x 0.05) |
(G) Clerical Hours per Year (G= E x 0.1) |
Total Labor Costs per Year b |
|
|
|
| 1. Applications |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
|
Labor Rates |
| 2. Surveys and Studies |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
|
Management |
$157.61 |
| 3. Reporting Requirements |
|
|
|
|
|
|
|
|
|
Technical |
$123.94 |
| A. Familiarization with Regulatory Requirements |
1 |
1 |
1 |
116 |
116 |
5.8 |
11.6 |
$16,016.41 |
|
Clerical |
$62.52 |
| B. Required Activities |
|
|
|
|
|
|
|
|
|
|
|
| i. Initial performance tests |
24 |
1 |
24 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| ii. Repeat performance testsc |
24 |
1 |
24 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| C. Create Information |
See 3B |
|
|
|
|
|
|
|
|
|
|
| D. Gather Existing Information |
See 3E |
|
|
|
|
|
|
|
|
|
|
| E. Write Report |
|
|
|
|
|
|
|
|
|
|
|
| i. Notification of Construction/Reconstruction d |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| ii. Notification of Anticipated Startup d |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| iii. Notification of Actual Startup e |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| iv. Notification of Initial Performance Test d |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| v. Report of Performance Test |
See 3B |
|
|
|
|
|
|
|
|
|
|
| vi. Semiannual Work Practice Reports e, f |
30 |
2 |
60 |
116 |
6,960 |
348 |
696 |
$960,984.60 |
|
|
|
| Subtotal for Reporting Requirements |
|
|
|
|
8,137 |
$977,001 |
|
|
|
| 4. Recordkeeping Requirements |
|
|
|
|
|
|
|
|
|
|
|
| A. Familiarization with Regulatory Requirements |
See 3A |
|
|
|
|
|
|
|
|
|
|
| B. Plan Activities |
See 3B |
|
|
|
|
|
|
|
|
|
|
| C. Implement Activities |
See 3B |
|
|
|
|
|
|
|
|
|
|
| D. Develop Record System |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
|
|
|
| E. Time to Enter Information |
|
|
|
|
|
|
|
|
|
|
|
| i. Records of Operating Parameters f, g |
2.5 |
365 |
912.5 |
116 |
105,850 |
5,292.5 |
10,585 |
$14,614,974.13 |
|
|
|
| F. Train Personnel |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
|
|
|
| G. Audits |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
|
|
|
| Subtotal for Recordkeeping Requirements |
|
|
|
|
121,728 |
$14,614,974 |
|
|
|
| Total Labor Burden and Costs (rounded) h |
|
|
|
|
130,000 |
$15,600,000 |
|
|
|
| Total Capital and O&M Costs (rounded) h |
|
|
|
|
|
|
|
$0 |
|
hr/response |
|
| Grand Total (rounded) h |
|
|
|
|
130,000 |
$15,600,000 |
|
560 |
|
|
|
|
|
| Assumptions |
|
|
|
|
|
|
|
|
|
|
|
| a We assume that 116 existing refineries per year will be subject to requirements of NSPS Subpart GGG during the three-year period of this ICR. This rule applies to facilities that commenced construction, reconstruction, or modification prior to November 7, 2006. All facilities that commence construction, reconstruction, or modification after November 7, 2006 are subject to Subpart GGGa. |
|
|
|
| b This ICR uses the following labor rates: $157.61 ($75.05 + 110%) for managerial, $123.94 ($59.02 + 110%) for technical, and $62.52 ($29.77 + 110%) for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2021, “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 varying industry wage rates and the additional overhead business costs of employing workers beyond their wages and benefits, including business expenses associated with hiring, training, and equipping their employees. |
|
|
|
| c Assume 20 percent of initial performance tests must repeat due to failure. |
|
|
|
| d Owners or operators of the affected facilities must make one-time-only notifications. |
|
|
|
| e The time to prepare reports is estimated to be the same under both Subparts because the information in the new records must be maintained on-site, but it does not have to be reported. |
|
|
|
| f Assume that average number of affected facilities over the next three years is equal to the current number of facilities (116) because affected facilities after November 7, 2006 will be subject to Subpart GGGa instead of Subpart GGG. |
|
|
|
| g Although monitoring of the various components may be required on a weekly, monthly, quarterly, semiannual or annual basis, given the number of components that must be monitored at any facility, monitoring overall occurs daily. It is also assumed that it takes about 3 minutes per calibration and large facilities have about 25 monitors calibrated about twice per day. Therefore, it is assumed that the average recordkeeping time for each day’s worth of monitoring for Subpart GGG is 2.5 hours (0.05 hours/calibration x 25 monitors x 2 calibrations/monitor/day) and that monitoring is done 365 days a year. |
|
|
|
| h Totals are rounded to three significant figures. Figures may not add exactly due to rounding. |
|
|
|
| Table 1b: Annual Respondent Burden and Cost - NSPS for Equipment Leaks of VOC in Petroleum Refineries (40 CFR Part 60, Subpart GGGa) (Renewal) |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| Burden Item |
(A) Respondent Hours per Occurrence (Technical hours) |
(B) Number of Occurrences per Respondent per Year |
(C) Hours per Respondent per Year (C=A x B) |
(D) Number of Respondents per Year a |
(E) Technical Hours per Year (E=C x D) |
(F) Management Hours per Year (F= E x 0.05) |
(G) Clerical Hours per Year (G= E x 0.1) |
Total Labor Costs per Year b |
|
|
|
| 1. Applications |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
|
Labor Rates |
| 2. Surveys and studies |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
|
Management |
$157.61 |
| 3. Reporting Requirements |
|
|
|
|
|
|
|
|
|
Technical |
$123.94 |
| A. Familiarization with Regulatory Requirements |
1 |
1 |
1 |
46 |
46 |
2.3 |
4.6 |
$6,351.34 |
|
Clerical |
$62.52 |
| B. Required Activities |
|
|
|
|
|
|
|
|
|
|
|
| i. Initial Performance Tests |
24 |
1 |
24 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| ii. Repeat performance tests c |
24 |
1 |
24 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| C. Create Information |
See 3B |
|
|
|
|
|
|
|
|
|
|
| D. Gather Existing Information |
See 3E |
|
|
|
|
|
|
|
|
|
|
| E. Write Report |
|
|
|
|
|
|
|
|
|
|
|
| i. Notification of Construction/Reconstruction d |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| ii. Notification of Anticipated Startup d |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| iii. Notification of Actual Startup d |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| iv. Notification of Initial Performance Test d |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| v. Report of Performance Test |
See 3B |
|
|
|
|
|
|
|
|
|
|
| vi. Semiannual Work Practice Reports at Large Refineries e, f |
30 |
2 |
60 |
34.5 |
2,070 |
104 |
207 |
$285,810.08 |
|
|
|
| vii. Semiannual Work Practice Reports at Small Refineries e, f |
8 |
2 |
16 |
11.5 |
184 |
9.2 |
18 |
$25,405.34 |
|
|
|
| Subtotal for Reporting Requirements |
|
|
|
|
2,645 |
$317,567 |
|
|
|
| 4. Recordkeeping Requirements |
|
|
|
|
|
|
|
|
|
|
|
| A. Familiarization with Regulatory Requirements |
See 3A |
|
|
|
|
|
|
|
|
|
|
| B. Plan Activities |
See 3B |
|
|
|
|
|
|
|
|
|
|
| C. Implement Activities |
See 3B |
|
|
|
|
|
|
|
|
|
|
| D. Develop Record System |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
|
|
|
| E. Time to Enter Information |
|
|
|
|
|
|
|
|
|
|
|
| i. Records of Operating Parameters at Large Refineries g, h |
2.64 |
365 |
964 |
40.25 |
38,785 |
1,939 |
3,878 |
$5,355,128.11 |
|
|
|
| ii. Records of Operating Parameters at Small Refineries g, h |
2.66 |
365 |
971 |
5.75 |
5,583 |
279 |
558 |
$770,813.89 |
|
|
|
| F. Train Personnel |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
|
|
|
| G. Audits |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
|
|
|
| Subtotal for Recordkeeping Requirements |
|
|
|
|
51,023 |
$6,125,942 |
|
|
|
| Total Labor Burden and Costs (rounded) i |
|
|
|
|
53,700 |
$6,440,000 |
|
|
|
| Total Capital and O&M Costs (rounded) i |
|
|
|
|
|
|
|
$0 |
|
hr/response |
|
| Grand Total (rounded) i |
|
|
|
|
53,700 |
$6,440,000 |
|
584 |
|
|
|
|
|
|
|
|
|
|
|
|
|
| Assumptions |
|
|
|
|
|
|
|
|
|
|
|
| a We assume that an average of 46 refineries per year will be subject to the requirements of NSPS Subpart GGGa and that no new refineries will become subject to the rule during the three-year period of this ICR. All facilities that commence construction, reconstruction, or modification after November 7, 2006 are subject to Subpart GGGa. |
|
|
|
| b This ICR uses the following labor rates: $157.61 ($75.05 + 110%) for managerial, $123.94 ($59.02 + 110%) for technical, and $62.52 ($29.77 + 110%) for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2021, “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 varying industry wage rates and the additional overhead business costs of employing workers beyond their wages and benefits, including business expenses associated with hiring, training, and equipping their employees. |
|
|
|
| c Assume 20% of initial performance tests must repeat due to failure. |
|
|
|
| d Owners or operators of the affected facilities must make one-time-only notifications. |
|
|
|
| e The time to prepare reports is estimated to be the same under both subparts because the information in the new records must be maintained on-site, but it does not have to be reported. |
|
|
|
| f Assume that 25 percent of the process units are located at small refineries (25% x 46 = 11.5). The rest are large facilities (75% x 46 = 34.5). Small facilities have fewer leaks and deviations so they can complete reports in less time. Larger facilities require significantly more time to complete reports. |
|
|
|
g Although monitoring of the various components may be required on a weekly, monthly, quarterly, semiannual or annual basis, given the number of components that must be monitored at any facility, monitoring overall occurs daily.
Assume that large facilities need an additional 0.14 hours per day to complete the tasks required by the new standards. Therefore, it is assumed that the average recordkeeping time for each day’s worth of monitoring for large facilities for Subpart GGGa is 2.64 hours and that monitoring is done 365 days a year. See Table 1a, Footnote G for the calculation for the time for calibration.
Small facilities may record instrument readings manually, so an additional 0.02 hours per day are needed for small refineries with manual recordkeeping of instrument readings. Therefore, it is assumed that the average recordkeeping time for each day’s worth of monitoring for small facilities for Subpart GGGa is 2.66 hours and that monitoring is done 365 days a year. |
|
|
|
| h Assume that 25 percent of the process units are located at small refineries and half of those use manual recordkeeping of instrument readings (46 x 25% x 0.5 = 5.75) and that 75 percent of the process units are located at large refineries (46 x 75% = 34.5) and thus the number of process units that do not need additional time for manual recordkeeping is (5.75 + 34.5 = 40.25) |
|
|
|
| i Totals are rounded to three significant figures. Figures may not add exactly due to rounding. |
|
|
|
| Table 2a: Annual Agency Burden and Cost - NSPS for Equipment Leaks of VOC in Petroleum Refineries (40 CFR Part 60, Subpart GGG) (Renewal) |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| Burden Item |
(A) EPA Person-Hours per Occurrence |
(B) Annual Occurrences per Respondent |
(C) EPA Hours per Year (A x B) |
(D) Plants per Year a |
(E) Technical Hours per Year (C x D) |
(F) Management Hours per Year (E x 0.05) |
(G) Clerical Hours per Year (E x 0.1) |
(H)
Annual Cost b |
|
|
|
| Performance Test Report Review (New Plants) |
4 |
1.2 |
4.8 |
0 |
0 |
0 |
0 |
$0 |
|
Labor Rates |
| Notification of Construction |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
|
Management |
$70.56 |
| Notification of Anticipated Startup |
0.5 |
1 |
0.5 |
0 |
0 |
0 |
0 |
$0 |
|
Technical |
$52.37 |
| Notification of Actual Startup |
0.5 |
1 |
0.5 |
0 |
0 |
0 |
0 |
$0 |
|
Clerical |
$28.34 |
| Notification of Initial Test |
0.5 |
1.2 |
0.6 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| Review Test Results |
8 |
1.2 |
9.6 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| Report Review (Existing Plants) |
4 |
2 |
8 |
116 |
928 |
46.4 |
92.8 |
$54,503.30 |
|
|
|
| TOTAL (rounded) c |
|
|
|
|
1,070 |
$54,500 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| Assumptions |
|
|
|
|
|
|
|
|
|
|
|
| a We assume that 116 existing refineries per year will be subject to requirements of NSPS Subpart GGG during the three-year period of this ICR. This rule applies to facilities that commenced construction, reconstruction, or modification prior to November 7, 2006. All facilities that commence construction, reconstruction, or modification after November 7, 2006 are subject to Subpart GGGa. |
|
|
|
| b This ICR uses the following labor rates: $70.56 (GS-13, Step 5, $44.10 + 60%) for managerial, $52.37 (GS-12, Step 1, $32.73 + 60%) for technical, and $28.34 (GS-6, Step 3, $17.71 + 60%) for clerical labor. These rates are from the Office of Personnel Management (OPM), 2022 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 are rounded to three significant figures. Figures may not add exactly due to rounding. |
|
|
|
| Table 2b: Annual Agency Burden and Cost - NSPS for Equipment Leaks of VOC in Petroleum Refineries (40 CFR Part 60, Subpart GGGa) (Renewal) |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| Burden Item |
(A)
EPA Person-Hours per Occurrence |
(B) Annual Occurrences per Respondent |
(C) EPA Hours per Year (A x B) |
(D) Plants per Year a |
(E) Technical Hours per Year (C x D) |
(F) Management Hours per Year (E x 0.05) |
(G) Clerical Hours per Year (E x 0.1) |
(H)
Annual Cost b |
|
|
|
| Performance Test Report Review (New Plants) |
4 |
1.2 |
4.8 |
0 |
0 |
0 |
0 |
$0 |
|
Labor Rates |
| Notification of Construction |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
|
Management |
$70.56 |
| Notification of Anticipated Startup |
0.50 |
1 |
0.5 |
0 |
0 |
0 |
0 |
$0 |
|
Technical |
$52.37 |
| Notification of Actual Startup |
0.50 |
1 |
0.5 |
0 |
0 |
0 |
0 |
$0 |
|
Clerical |
$28.34 |
| Notification of Initial Test |
0.50 |
1.2 |
0.6 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| Review Test Results |
8.00 |
1.2 |
9.6 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| Report Review (Existing Plants) |
4 |
2 |
8 |
46 |
368 |
18.4 |
36.8 |
$21,613.38 |
|
Total |
|
| TOTAL (rounded) c |
|
|
|
|
423 |
$21,600 |
|
$76,100 |
|
|
|
|
|
|
|
|
|
|
|
|
|
| Assumptions |
|
|
|
|
|
|
|
|
|
|
|
| a We assume that an average of 46 refineries per year will be subject to the requirements of NSPS Subpart GGGa and that no new refineries will become subject to the rule during the three-year period of this ICR. All facilities that commence construction, reconstruction, or modification after November 7, 2006 are subject to Subpart GGGa. |
|
|
|
| b This ICR uses the following labor rates: $70.56 (GS-13, Step 5, $44.10 + 60%) for managerial, $52.37 (GS-12, Step 1, $32.73 + 60%) for technical, and $28.34 (GS-6, Step 3, $17.71 + 60%) for clerical labor. These rates are from the Office of Personnel Management (OPM), 2022 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 are rounded to three significant figures. Figures may not add exactly due to rounding. |
|
|
|
| Total Annual Responses |
| (A) |
(B) |
(C) |
(D) |
(E) |
| Information Collection Activity |
Number of Respondents a |
Number of Responses |
Number of Existing Respondents That Keep Records But Do Not Submit Reports |
Total Annual Responses E=(BxC)+D |
| Subpart GGG |
| 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 performance test |
0 |
1 |
0 |
0 |
| Performance test report |
0 |
1 |
0 |
0 |
| Semiannual report |
116 |
2 |
0 |
232 |
| Subpart GGGa |
| 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 performance test |
0 |
1 |
0 |
0 |
| Performance test report |
0 |
1 |
0 |
0 |
| Semiannual report |
46 |
2 |
0 |
92 |
|
|
|
Total |
324 |
|
|
|
|
|
| a We assume that 116 existing refineries per year will be subject to requirements of NSPS Subpart GGG during the three-year period of this ICR. This rule applies to facilities that commenced construction, reconstruction, or modification prior to November 7, 2006. We assume that an average of 46 refineries per year will be subject to the requirements of NSPS Subpart GGGa and that no new refineries will become subject to the rule during the three-year period of this ICR. All facilities that commence construction, reconstruction, or modification after November 7, 2006 are subject to Subpart GGGa. |
| Number of Respondents |
|
Respondents That Submit Reports |
Respondents That Do Not Submit Any Reports |
|
|
(A) |
(B) |
(C) |
(D) |
(E) |
| Year |
Number of New Respondents a |
Number of Existing Respondents b |
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) |
| 1 |
0 |
116 |
0 |
0 |
116 |
| 2 |
0 |
116 |
0 |
0 |
116 |
| 3 |
0 |
116 |
0 |
0 |
116 |
| Average |
0 |
116 |
0 |
0 |
116 |
| a New respondents include sources with constructed, reconstructed, and modified affected facilities. |
| b Over the next three years, approximately 116 respondents per year will be subject to Subpart GGG. In addition, it is assumed that 46 of these 116 refineries are also subject to Subpart GGGa. |