Burden Calculation Tables

1854t14.xlsx

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

Burden Calculation Tables

OMB: 2060-0443

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Overview

Summary
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: Summary

ICR Summary Information
Hours per Response 327
Number of Respondents 1,346
Total Estimated Burden Hours 1,220,000
Total Estimated Costs $219,000,000
Annualized Capital O&M $65,200,000
Total Annual Responses 3,736
Form Number Not Applicable

Sheet 2: 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 10 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 10 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 3: 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 No updates, retained prior estimate.
2 0 10 0 0 10
3 0 10 0 0 10
Average 0 10 0 0 10
NSPS Kb
1 0 385 0 0 385 Updated based on 1854.13
2 0 385 0 0 385
3 0 385 0 0 385
Average 0 385 0 0 385
NSPS VV
1 0 170 0 0 170 No updates, retained prior estimate.
2 0 170 0 0 170
3 0 170 0 0 170
Average 0 170 0 0 170
NSPS VVa
1 0 75 0 0 75 No updates, retained prior estimate but set growth rate to 0.
2 0 75 0 0 75
3 0 75 0 0 75
Average 0 75 0 0 75
NSPS DDD
1 5 83 0 0 88 No updates, adjusted prior estimate assuming same growth rate.
2 5 88 0 0 93
3 5 93 0 0 98
Average 5 88 0 0 93
NSPS III
1 0 40 0 0 40 No updates, retained prior estimate but set growth rate to 0.
2 0 40 0 0 40
3 0 40 0 0 40
Average 0 40 0 0 40
NSPS NNN
1 0 136 0 0 136 No updates, retained prior estimate but set growth rate to 0.
2 0 136 0 0 136
3 0 136 0 0 136
Average 0 136 0 0 136
NSPS RRR
1 0 74 0 0 74 No updates, retained prior estimate but set growth rate to 0.
2 0 74 0 0 74
3 0 74 0 0 74
Average 0 74 0 0 74
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.
2 0 67 0 0 67
3 0 67 0 0 67
Average 0 67 0 0 67
HON
1 0.67 209 0 0 210 Updated based on recent proposed rulemaking; we assume only 10% of these sources will comply with CAR.
2 0.67 210 0 0 211
3 0.67 212 0 0 212
Average 0.67 210 0 0 211



















1319

Sheet 4: 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 5: Table 2

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












$54.51 $73.46 $29.50
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Average hours per activity Number of activities per respondent per year Estimated Technical hours per plant per year
(C=AxB)
Sources per year Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) 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 94 940 47 94 $57,465.02
3. Review periodic reports d 4 1 4 21 84.13 4.21 8.41 $5,143.32
TOTAL (rounded) e



1,180 $63,000









Assumptions:







a This cost is based on the average hourly labor rate as follows: Managerial $73.46 (GS-13, Step 5, $45.91 + 60%); Technical $54.51 (GS-12, Step 1, $34.07 + 60%); and Clerical $29.50 (GS-6, Step 3, $18.44 + 60%). This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. These rates are from the Office of Personnel Management (OPM), 2023 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 94 equipment leak sources will comply with the CAR (63 from the HON, 23 from subpart VV and 8 from subpart V - see Table 4). Reports for equipment leaks will be submitted semiannually (94 x 2 = 188 per year). See Attachment C for assumptions and further description of activities.
d We estimate 10 percent of the 210 SOCMI facilities, which equals 21 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 6: Table 3

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












$54.51 $73.46 $29.50
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Technical person-hours per occurrence No. of occurrences per respondent per year Technical person-hours per respondent per year
(C=AxB)
Respondents per year Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) a
Report review/filing 1 1 1 6 6 0.3 0.6 $366.80
TOTAL (rounded) b



7 $367









Assumptions:







a This cost is based on the average hourly labor rate as follows: Managerial $73.46 (GS-13, Step 5, $45.91 + 60%); Technical $54.51 (GS-12, Step 1, $34.07 + 60%); and Clerical $29.50 (GS-6, Step 3, $18.44 + 60%). This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. These rates are from the Office of Personnel Management (OPM), 2023 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 7: 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 25
The number of affected sources under each reference subpart were adjusted to reflect the revised inventory of
Kb 175
facilities under each subpart.
Y 0
To do so, we back calculated 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 DDD, we took 3 process vents/5%/78 respondents to estimate 0.77 process vents per facility.
Equipment Leaks

Then we applied 0.77 process vents x 93 facilities (revised inventory) x 5% complying with CAR = 4 affected sources.
V 8
For subparts BB, V, and HON sources, we divided by 25% to match the assumptions in the previous ICR but adjusted the new estimates by 10% based on feedback from OAQPS.
VV 23
VVa 0

Process Vents


III 2

NNN 4

RRR 2

DDD 4

HON F & G - Storage Vessels 211

HON F & G - Transfer Racks 84

HON H &I -- Equipment Leaks 63

HON F & G - Process Vents 169





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 10 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 10 percent of HON sources will opt to comply with the CAR. Numbers of sources are rounded to the nearest whole number.

Sheet 8: 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 2.9 525 1.1 452 1.1 92 2.5 158 1 31 1.8 37.9 1,296
2. Plan activities 2.1 380 1.7 699 0.85 71 0.57 36 0.23 7.1 4.5 95 1,288
3. Training 1.3 235 0.5 206 0.5 42 0 0 0 0 0 0 483
4. Creation, testing, research and development 28 5,068 16 6,576 16 1,344 380 23,940 155 4,805 0 0 41,733
5. Gather information, monitor/ inspect 14 2,534 17 6,987 17 1,428 263 16,569 108 3,348 54 1,136 32,002
6. Process/compile and review 0 0 0 0 0 0 0 0 0 0 18 379 379
7. Complete forms 9 1,629 5.4 2,219 5.4 454 57 3,591 23 713 5.4 114 8,720
8. Record/disclose 28 5,068 2.8 1,151 2.8 235 4.7 296 1.9 58.9 9 189 6,998
9. Store/file 3 543 1.25 514 1.25 105 2.75 173 0.9 27.9 1.58 33.2 1,396
TOTAL 88 15,982 46 18,803 45 3,772 711 44,763 290 8,991 94 1,983 94,294














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 - 181












- storage vessels - 411












- transfer racks - 84












- equipment leaks with connector monitoring - 63












- equipment leaks without connector monitoring - 31












- facilities (used for inventory estimate) - 21












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 9: Table 6

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











$130.28 $163.17 $65.71

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 2.68 23 61.6 1,296 65 130 $187,897.51
2. Plan activities 4.7 13 61.2 1,288 64 129 $186,756.28
3. Training 5.74 4 23.0 483 24.1 48.3 $70,010.59
4. Creation, testing, research, and development 20.0 99 1,984 41,733 2,087 4,173 $6,051,681.46
5. Gather information, monitor/inspect 2.2 677 1,521 32,002 1,600 3,200 $4,640,565.02
6. Process/compile and review 18 1 18.0 379 18.9 38 $54,900.60
7. Complete forms 82.9 5 415 8,720 436 872 $1,264,421.94
8. Record/disclose 12.8 26 333 6,998 350 700 $1,014,819.98
9. Store/file 1.90 35 66.4 1,396 70 140 $202,452.50
TOTAL LABOR BURDEN AND COST (rounded) c


108,000 $13,700,000
TOTAL CAPITAL AND O&M COST (rounded) c





$5,780,000
GRAND TOTAL (rounded) c





$19,500,000









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 21 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: Managerial $163.17 ($77.70 + 110%); Technical $130.28 ($62.04 + 110%); and Clerical $65.71 ($31.29 + 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2022, “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.
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 7

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












$130.28 $163.17 $65.71
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Technical person-hours per occurrence No. of occurrences per respondent per year Technical person-hours per respondent per year
(C=AxB)
Respondents per year Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) 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 $435.03
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 $435.03
Subtotal for Reporting Requirements



7 $870
5. Recordkeeping requirements







A. Familiarize with regulatory requirements See 4A






Subtotal for Recordkeeping Requirements



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



7 $870
TOTAL CAPITAL AND O&M COST (rounded) c






$0
GRAND TOTAL (rounded) c






$870









Assumptions:







a This ICR uses the following labor rates: Managerial $163.17 ($77.70 + 110%); Technical $130.28 ($62.04 + 110%); and Clerical $65.71 ($31.29 + 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2022, “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
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 11: 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 $337,919 7 $356 $0 $0
NSPS Kb 385 983 13,515 40,184 53,699 $6,771,201 246 $13,074 $293,659 $0
NSPS VV 170 340 1,760 15,640 17,400 $2,193,994 782 $41,570 $0 $0
NSPS VVa 75 150 863 7,717 8,580 $1,081,843 423 $22,466 $0 $0
NSPS DDD 93 198 3,229 1,005 4,234 $533,925 483 $25,676 $651,000 $150,000
NSPS III 40 80 322 439 761 $95,996 184 $9,781 $54,000 $0
NSPS NNN 136 272 1,095 1,447 2,542 $320,471 626 $33,256 $183,600 $0
NSPS RRR 74 148 596 787 1,383 $174,374 340 $18,095 $37,000 $0
NESHAP BB 54 216 7,662 4,844 12,506 $1,576,978 497 $26,409 $0 $0
NESHAP Y 4 8.08 60 9 69 $8,464 9 $489 $0 $0
NESHAP V 67 134 4,700 4,418 9,118 $1,149,795 308 $16,384 $0 $0
NESHAP F, G, H, and I 211 1,084 852,875 145,780 998,655 $125,925,631 3,325 $176,766 $58,025,000 $23,667
CAR d 21 105 98,784 9,654 108,438 $13,673,506 1,178 $62,608 $5,784,167 $0
CAR Revisions e 6 6 7 0 7 $870 7 $367 $0 $0 hr/response
TOTAL f 1,346 3,736 986,000 235,000 1,220,000 $154,000,000 8,410 $447,000 $65,000,000 $174,000 327












Assumptions:









$65,200,000
a From Tables G-1 through G-13.









$219,000,000
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 12: 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 0 1 0 0
Notification of actual startup 0 1 0 0
Notification of IFR internal inspection 0 1 0 0
Notification of EFR gap measurement 0 1 0 0
IFR internal inspection report 0 1 0 0
EFR 1st seal gap measurement 0 1 0 0
EFR 2nd seal gap measurement 0 1 0 0
CVS operating plan report 0 1 0 0
Report of IFR failure 34.7 1 0 34.7
Notification of IFR delay of repair/emptying 3.5 1 0 3.5
EFR 1st seal gap measurement report 385 1 0 385
EFR 2nd seal gap measurement report 385 1 0 385
Notification of refill 175 1 0 175



Subtotal 983
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 0 1 0 0
Repeat performance test report 0 1 0 0
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 75 2 0 150



Subtotal 150
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 88 2 0 176



Subtotal 198
NSPS III
Initial performance test report 0 1 0 0
Repeat performance test report 0 1 0 0
Notification of construction/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 40 2 0 80



Subtotal 80
NSPS NNN
Initial performance test report 0 1 0 0
Repeat performance test report 0 1 0 0
Notification of construction/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 136 2 0 272



Subtotal 272
NSPS RRR
Initial performance test report 0 1 0 0
Repeat performance test report 0 1 0 0
Notification of construction/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 74 2 0 148



Subtotal 148
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) 0.67 49 0 32.67
Complete reports (existing respondents; see Table G-13) 210 5 0 1051.67



Subtotal 1,084
CAR Provisions
Complete forms (see Table 6) 21 5 0 105



Subtotal 105
CAR Direct Final Standards
Write report (see Table 7) 6 1 0 6



Subtotal 6

Total responses (all subparts) 3,736

Sheet 13: Table F-1

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












$54.51 $73.46 $29.50
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) 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 $336.23
Report of gap excesses d, e 1 1 1 0.33 0.33 0.02 0.03 $20.17
TOTAL (rounded) f



6.7 $356









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 cost is based on the average hourly labor rate as follows: Managerial $73.46 (GS-13, Step 5, $45.91 + 60%); Technical $54.51 (GS-12, Step 1, $34.07 + 60%); and Clerical $29.50 (GS-6, Step 3, $18.44 + 60%). This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. These rates are from the Office of Personnel Management (OPM), 2023 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 14: Table F-2

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












$54.51 $73.46 $29.50
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) b
Report review: New plant






Notification of construction 2 1 2 0 0 0 0 $0.00
Notification of anticipated startup 1 1 1 0 0 0 0 $0.00
Notification of actual startup 1 1 1 0 0 0 0 $0.00
Notification of initial inspection 1 1 1 0 0 0 0 $0.00
Report review: New and Existing plants






IFR failure report c 1 1 1 35 34.7 1.735 3.47 $2,121.32
Notification of IFR delay of repair/emptying d 1.2 1 1.2 3.5 4.2 0.21 0.4 $254.56
Notification of refill e 1 1 1 175 175 8.8 17.5 $10,698.28
TOTAL (rounded) f



246 $13,100









Assumptions:







a We have assumed that the average number of respondents that will be subject to revised requirements will be 385 per year. This is based on our estimate of 3,500 existing IFR storage vessels subject to the NSPS.
b This cost is based on the average hourly labor rate as follows: Managerial $73.46 (GS-13, Step 5, $45.91 + 60%); Technical $54.51 (GS-12, Step 1, $34.07 + 60%); and Clerical $29.50 (GS-6, Step 3, $18.44 + 60%). This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. These rates are from the Office of Personnel Management (OPM), 2023 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 90% of existing and new respondents ((385+0) x 0.9 = 347) will choose visual inspections. We estimate 10 percent failure rate for the 347 respondents choosing annual visual inspections, yielding 35 reports. (347 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 We assumed degassing would occur every 20 years for maintenance in the absence of the internal inspection requirement. Without the internal inspection requirement, there would be 175 degassing and emptying events per year (3500/20).
f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

Sheet 15: Table F-3

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












$54.51 $73.46 $29.50
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) 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 $41,570.44
TOTAL (rounded) c



782 $41,600









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 cost is based on the average hourly labor rate as follows: Managerial $73.46 (GS-13, Step 5, $45.91 + 60%); Technical $54.51 (GS-12, Step 1, $34.07 + 60%); and Clerical $29.50 (GS-6, Step 3, $18.44 + 60%). This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. These rates are from the Office of Personnel Management (OPM), 2023 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 16: Table F-4

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












$54.51 $73.46 $29.50
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) b
Report review: New plant






Notification of construction c 8 1 8 0 0 0 0 $0.00
Notification of reconstruction/ modification c 2 1 2 0 0 0 0 $0.00
Notification of actual startup 0.5 1 0.5 0 0 0.00 0 $0.00
Notification of initial/repeat test d 0.5 1 0.5 0 0 0.00 0 $0.00
Review test results d 2 1 2 0 0 0 0 $0.00
Report review: Existing plant







Semiannual emission report 2.45 2 4.9 75 368 18.4 36.8 $22,466.38
TOTAL (rounded) e



423 $22,500









Assumptions:







a Assume there will be no new, modified, or reconstructed facilities each year and an average of 75 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 cost is based on the average hourly labor rate as follows: Managerial $73.46 (GS-13, Step 5, $45.91 + 60%); Technical $54.51 (GS-12, Step 1, $34.07 + 60%); and Clerical $29.50 (GS-6, Step 3, $18.44 + 60%). This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. These rates are from the Office of Personnel Management (OPM), 2023 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 no new sources will be constructed and no existing sources will be modified/reconstructed.
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 17: Table F-5

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












$54.51 $73.46 $29.50
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) b
Report review: New plant






Notification of construction/ modification 2 1 2 5 10 0.5 1 $611.33
Notification of actual startup 2 1 2 5 10 0.5 1 $611.33
Initial performance test 8 1 8 5 40 2 4 $2,445.32
Repeat performance test c 8 1 8 1 8 0.4 0.8 $489.06
Report review: Existing plant







Semiannual report 2 2 4 88 352 17.6 35.2 $21,518.82
TOTAL (rounded) d



483 $25,700









Assumptions:







a We assume 5 new affected sources per year and an average of 88 existing affected sources over the next three years.
b This cost is based on the average hourly labor rate as follows: Managerial $73.46 (GS-13, Step 5, $45.91 + 60%); Technical $54.51 (GS-12, Step 1, $34.07 + 60%); and Clerical $29.50 (GS-6, Step 3, $18.44 + 60%). This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. These rates are from the Office of Personnel Management (OPM), 2023 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-6

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












$54.51 $73.46 $29.50
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) b
Report review: New plant






Notification of construction/ modification 2 1 2 0 0 0 0 $0.00
Notification of anticipated startup 2 1 2 0 0 0 0 $0.00
Notification of actual startup 2 1 2 0 0 0 0 $0.00
Initial performance test 8 1 8 0 0 0 0 $0.00
Repeat performance test c 8 1 8 0 0 0.0 0.0 $0.00
Report review: Existing plant







Semiannual report 2 2 4 40 160 8 16 $9,781.28
TOTAL (rounded) d



184 $9,780









Assumptions:







a Assume no new affected sources per year and an average of 40 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 cost is based on the average hourly labor rate as follows: Managerial $73.46 (GS-13, Step 5, $45.91 + 60%); Technical $54.51 (GS-12, Step 1, $34.07 + 60%); and Clerical $29.50 (GS-6, Step 3, $18.44 + 60%). This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. These rates are from the Office of Personnel Management (OPM), 2023 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-7

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












$54.51 $73.46 $29.50
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) b
Report review: New plant






Notification of construction/ modification 2 1 2 0 0 0 0 $0.00
Notification of actual startup 2 1 2 0 0 0 0 $0.00
Initial performance test 8 1 8 0 0 0 0 $0.00
Repeat performance test c 8 1 8 0 0 0 0 $0.00
Report review: Existing plant







Semiannual report 2 2 4 136 544 27.2 54.4 $33,256.35
TOTAL (rounded) d



626 $33,300









Assumptions:







a Assume no new affected sources per year subject to subpart NNN and not the HON. We assume 136 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 cost is based on the average hourly labor rate as follows: Managerial $73.46 (GS-13, Step 5, $45.91 + 60%); Technical $54.51 (GS-12, Step 1, $34.07 + 60%); and Clerical $29.50 (GS-6, Step 3, $18.44 + 60%). This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. These rates are from the Office of Personnel Management (OPM), 2023 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-8

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












$54.51 $73.46 $29.50
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) b
Report review: New plant






Notification of construction/ modification 2 1 2 0 0 0 0 $0.00
Notification of actual startup 2 1 2 0 0 0 0 $0.00
Initial performance test 8 1 8 0 0 0 0 $0.00
Repeat performance test c 8 1 8 0 0 0 0 $0.00
Report review: Existing plant







Semiannual report 2 2 4 74 296 14.8 29.6 $18,095.37
TOTAL (rounded) d



340 $18,100









Assumptions:







a Assume no new affected sources per year subject to subpart RRR and not the HON. Assume 74 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 cost is based on the average hourly labor rate as follows: Managerial $73.46 (GS-13, Step 5, $45.91 + 60%); Technical $54.51 (GS-12, Step 1, $34.07 + 60%); and Clerical $29.50 (GS-6, Step 3, $18.44 + 60%). This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. These rates are from the Office of Personnel Management (OPM), 2023 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 21: Table F-9

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












$54.51 $73.46 $29.50
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) 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 $26,409.46
TOTAL (rounded) c



497 $26,400









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 cost is based on the average hourly labor rate as follows: Managerial $73.46 (GS-13, Step 5, $45.91 + 60%); Technical $54.51 (GS-12, Step 1, $34.07 + 60%); and Clerical $29.50 (GS-6, Step 3, $18.44 + 60%). This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. These rates are from the Office of Personnel Management (OPM), 2023 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 22: Table F-10

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












$54.51 $73.46 $29.50
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) 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 $489.06
Supplemental delay report d 1 1 1 0 0 0 0 $0
Quarterly emission report e N/A






TOTAL (rounded) f



9 $489









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 cost is based on the average hourly labor rate as follows: Managerial $73.46 (GS-13, Step 5, $45.91 + 60%); Technical $54.51 (GS-12, Step 1, $34.07 + 60%); and Clerical $29.50 (GS-6, Step 3, $18.44 + 60%). This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. These rates are from the Office of Personnel Management (OPM), 2023 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 23: Table F-11

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












$54.51 $73.46 $29.50
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) 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 $16,383.64
TOTAL (rounded) d



308 $16,400









Assumptions:







a Assume no new sources per year and 67 existing sources subject to Subpart V, but not the HON.
b This cost is based on the average hourly labor rate as follows: Managerial $73.46 (GS-13, Step 5, $45.91 + 60%); Technical $54.51 (GS-12, Step 1, $34.07 + 60%); and Clerical $29.50 (GS-6, Step 3, $18.44 + 60%). This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. These rates are from the Office of Personnel Management (OPM), 2023 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 24: Table F-12

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









$54.51 $73.46 $29.50

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 0.67 1.33 0.07 0.13 $81.51
2. Implementation plan or permit 20 0.67 13.33 0.67 1.33 $815.11
3. Compliance status 40 0.67 26.67 1.33 2.67 $1,630.21
4. Review equipment leak monitoring b 7 189 1,325 66 133 $81,007.34
5. Notification of construction/reconstruction 2 0.67 1.33 0.07 0.13 $81.51
6. Notification of anticipated startup 2 0.67 1.33 0.07 0.13 $81.51
7. Notification of actual startup 2 0.67 1.33 0.07 0.13 $81.51
8. Notification of performance test 2 0.67 1.33 0.07 0.13 $81.51
9. Review of test results 8 0.67 5.33 0.27 0.53 $326.04
10. Review periodic reports c 4 379 1,514 76 151 $92,579.82
TOTAL (rounded)

3,330 $177,000








Assumptions:






a This cost is based on the average hourly labor rate as follows: Managerial $73.46 (GS-13, Step 5, $45.91 + 60%); Technical $54.51 (GS-12, Step 1, $34.07 + 60%); and Clerical $29.50 (GS-6, Step 3, $18.44 + 60%). This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. These rates are from the Office of Personnel Management (OPM), 2023 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 189 existing sources out of the 210 total that will continue to comply with the HON.
c The 189 existing sources complying with the HON file semi-annual reports.

Sheet 25: Table G-1

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












$130.28 $163.17 $65.71
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) 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 $1,450.10
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 $1,305.09
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 $2,392.66
Report of seal gap excess e 2.5 1 2.5 0.33 0.8 0.04 0.1 $119.63
Information on vapor recovery See 3B






Subtotal for Reporting Requirements



42 $5,267
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 $326,271.38
Primary seal gap measurements d, e, g 2 10 20 2 40 2 4 $5,800.38
Fill/refill record h, i 0.2 10 2 2 4 0.2 0.4 $580.04
Subtotal for Recordkeeping Requirements



2,638 $332,652
TOTAL LABOR BURDEN AND COST (rounded) j



2,680 $338,000
TOTAL CAPITAL AND O&M COST (rounded) j






$0
GRAND TOTAL (rounded) j






$338,000









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: Managerial $163.17 ($77.70 + 110%); Technical $130.28 ($62.04 + 110%); and Clerical $65.71 ($31.29 + 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2022, “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 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 26: Table G-2

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












$130.28 $163.17 $65.71
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) b
1. Applications N/A






2. Survey and Studies N/A






3. Reporting requirements







A. Familiarize with regulatory requirements c 1 1 1 385 385 19 39 $55,828.66
B. Required activities







One-time-only requirements







Notification of construction 2 1 2 0 0 0 0 $0.00
Notification of actual startup 2 1 2 0 0 0 0 $0.00
Notification of physical/ operational changes d N/A






Notification of malfunction d N/A






Notification of initial inspection







IFR internal inspection 2 1 2 0 0 0.0 0.0 $0.00
EFR gap measurement 2 1 2 0 0 0 0.0 $0.00
Initial inspection report







IFR internal inspection report 12 1 12 0 0 0.0 0 $0.00
EFR 1st seal gap measurement 12 1 12 0 0 0.0 0.0 $0.00
EFR 2nd seal gap measurement 8 1 8 0 0 0.0 0.0 $0.00
CVS operating plan report 8 1 8 0 0 0 0 $0.00
Repeat requirements







Internal IFR inspection e 12 1 12 39 462 23 46 $66,994.39
Visual IFR inspection e 8 1 8 347 2,772 139 277 $401,966.33
Report of IFR failure e, f 2 1 2 35 69.4 3.47 7 $10,063.66
Notification of IFR delay of repair/emptying e, f, g 4 1 4 3.5 13.88 0.694 1.388 $2,012.73
EFR 1st seal gap measurement report 12 1 12 385 4,620 231 462 $669,943.89
EFR 2nd seal gap measurement report 8 1 8 385 3,080 154 308 $446,629.26
Notification of refill h 2 1 2 175 350 18 35 $50,753.33
Subtotal for Reporting Requirements



13,515 $1,704,192
4. Recordkeeping requirements







A. Familiarize with regulatory requirements c See 3A






B. Gather and record information







Vessel volumes, liquid vapor pressures, flares 8 1 8 385 3,080 154 308 $446,629.26
113b(a) inspection 12 1 12 385 4,620 231 462 $669,943.89
113b(b) gap measurement 12 1 12 385 4,620 231 462 $669,943.89
C. Develop record system N/A






D. Time to enter information







CVS parameter records 2 52 104 218 22,623 1,131 2,262 $3,280,491.91
E. Train personnel N/A






F. Audits N/A






Subtotal for Recordkeeping Requirements



40,184 $5,067,009
TOTAL LABOR BURDEN AND COST (rounded) i



53,700 $6,770,000
TOTAL CAPITAL AND O&M COST (rounded) i






$294,000
GRAND TOTAL (rounded) i






$7,060,000









Assumptions:







a We have assumed that the average number of respondents that will be subject to revised requirements will be 385 per year. This is based on our estimate of 3,500 existing IFR storage vessels subject to the NSPS.
b This ICR uses the following labor rates: Managerial $163.17 ($77.70 + 110%); Technical $130.28 ($62.04 + 110%); and Clerical $65.71 ($31.29 + 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2022, “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 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 385 existing respondents, we estimate that 90 percent (385 x 0.9 = 347) will conduct an annual visual inspection, while 10 percent (385 x 0.1 = 39, rounded) 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 90% of existing and new respondents ((385+0) x 0.9 = 347) will choose visual inspections. We estimate 10 percent failure rate for the 347 respondents choosing annual visual inspections, yielding 35 reports. (347 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 We assumed degassing would occur every 20 years for maintenance in the absence of the internal inspection requirement. Without the internal inspection requirement, there would be 175 degassing and emptying events per year (3500/20).
i Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

Sheet 27: Table G-3

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












$130.28 $163.17 $65.71
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) 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 $24,651.62
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 $197,212.92
Subtotal for Reporting Requirements



1,760 $221,865
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 $1,972,129.20
F. Train personnel N/A






G. Audits N/A






Subtotal for Recordkeeping Requirements



15,640 $1,972,129
TOTAL LABOR BURDEN AND COST (rounded) e



17,400 $2,190,000
TOTAL CAPITAL AND O&M COST (rounded) e






$0
GRAND TOTAL (rounded) e






$2,190,000









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: Managerial $163.17 ($77.70 + 110%); Technical $130.28 ($62.04 + 110%); and Clerical $65.71 ($31.29 + 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2022, “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 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 28: Table G-4

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












$130.28 $163.17 $65.71
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) b
1. Applications N/A






2. Survey and Studies N/A






3. Reporting requirements







A. Familiarize with regulatory requirements c 1 1 1 75 75 3.8 7.5 $10,875.71
B. Required activities







Initial performance test report 48 1 48 0 0 0 0 $0.00
Repeat performance test report d 48 1 48 0 0 0 0 $0.00
C. Create information See 3B






D. Gather existing information See 3E






E. Write report







Notification of construction e 2 1 2 0 0 0 0 $0.00
Notification of reconstruction/modification e 2 1 2 0 0 0 0 $0.00
Notification of actual startup 2 1 2 0 0 0 0.0 $0.00
Notification of initial/repeat performance test d 2 1 2 0 0 0 0 $0.00
Semiannual report 4.5 2 9 75 675 34 68 $97,881.41
Subpart for Reporting Requirements



863 $108,757
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 67 5,997 300 600 $869,549.47
Records of operating parameters - small facilities f 95.2 1 95.2 8 714.0 36 71 $103,536.78
F. Train personnel N/A






G. Audits N/A






Subtotal for Recordkeeping Requirements



7,717 $973,086
TOTAL LABOR BURDEN AND COST (rounded) g



8,580 $1,080,000
TOTAL CAPITAL AND O&M COST (rounded) g






$0
GRAND TOTAL (rounded) g






$1,080,000









Assumptions:







a Assume there will be an average of 0 new, modified, or reconstructed facilities each year and an average of 75 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: Managerial $163.17 ($77.70 + 110%); Technical $130.28 ($62.04 + 110%); and Clerical $65.71 ($31.29 + 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2022, “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 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 29: Table G-5

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












$130.28 $163.17 $65.71
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) b
1. Applications N/A






2. Survey and Studies N/A






3. Reporting requirements







A. Familiarize with regulatory requirements c 1 1 1 93 93 4.7 9.3 $13,485.88
B. Required activities







Initial performance test report 360 1 360 5 1,800 90 180 $261,017.10
Repeat performance test report d 360 1 360 1 360 18 36 $52,203.42
C. Write report







Notification of construction/modification 2 1 2 5 10 0.5 1 $1,450.10
Notification of actual startup 1 1 1 5 5 0.3 0.5 $725.05
Notification of initial/repeat performance test 2 1 2 6 12 0.6 1.2 $1,740.11
Semiannual report 3 2 6 88 528 26 53 $76,565.02
Subtotal for Reporting Requirements



3,229 $407,187
4. Recordkeeping requirements







Records of operating parameters for control devices 1 12 12 5 60 3 6 $8,700.57
Records of operating conditions exceeding last performance test 1 8 8 88 704 35 70 $102,086.69
Records of startup, shutdown, malfunction, etc. 0.25 5 1.25 88 110 5.5 11.0 $15,951.05
Subtotal for Recordkeeping Requirements



1,005 $126,738
TOTAL LABOR BURDEN AND COST (rounded) e



4,230 $534,000
TOTAL CAPITAL AND O&M COST (rounded) e






$801,000
GRAND TOTAL (rounded) e






$1,340,000









Assumptions:







a Assume 5 new affected sources per year and an average of 88 existing affected sources over the next three years, for an overall total of 93 sources.
b This ICR uses the following labor rates: Managerial $163.17 ($77.70 + 110%); Technical $130.28 ($62.04 + 110%); and Clerical $65.71 ($31.29 + 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2022, “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 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-6

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












$130.28 $163.17 $65.71
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) b
1. Applications N/A






2. Survey and Studies N/A






3. Reporting requirements







A. Familiarize with regulatory requirements c 1 1 1 40 40 2 4 $5,800.38
B. Required activities







Initial performance test report 60 1 60 0 0 0 0 $0.00
Repeat performance test report d 60 1 60 0 0 0 0 $0.00
C. Write report







Notification of construction/modification 2 1 2 0 0 0 0 $0.00
Notification of actual startup 1 1 1 0 0 0 0 $0.00
Notification of initial/repeat performance test 2 1 2 0 0 0.0 0.0 $0.00
Semiannual report 3 2 6 40 240 12 24 $34,802.28
Subtotal for Reporting Requirements



322 $40,603
4. Recordkeeping requirements







Records of operating parameters for control devices 1 12 12 1 12 0.6 1.2 $1,740.11
Records of operating conditions exceeding last performance test 1 8 8 40 320 16 32 $46,403.04
Records of startup, shutdown, malfunction, etc. 0.25 5 1.25 40 50 2.5 5.0 $7,250.48
Subtotal for Recordkeeping Requirements



439 $55,394
TOTAL LABOR BURDEN AND COST (rounded) e



761 $96,000
TOTAL CAPITAL AND O&M COST (rounded) e






$54,000
GRAND TOTAL (rounded) e






$150,000









Assumptions:







a Assume no new affected sources per year and an average of 40 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: Managerial $163.17 ($77.70 + 110%); Technical $130.28 ($62.04 + 110%); and Clerical $65.71 ($31.29 + 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2022, “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 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-7

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












$130.28 $163.17 $65.71
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) b
1. Applications N/A






2. Survey and Studies N/A






3. Reporting requirements







A. Familiarize with regulatory requirements c 1 1 1 136 136 6.8 14 $19,721.29
B. Required activities







Initial performance test report 60 1 60 0 0 0 0 $0.00
Repeat performance test report d 60 1 60 0 0 0 0 $0.00
C. Write report







Notification of construction/modification 2 1 2 0 0 0 0 $0.00
Notification of actual startup 1 1 1 0 0 0 0 $0.00
Notification of initial/repeat performance test 2 1 2 0 0 0.0 0.0 $0.00
Semiannual report 3 2 6 136 816 41 82 $118,327.75
Subtotal for Reporting Requirements



1,095 $138,049
4. Recordkeeping requirements







Records of operating parameters for control devices 1 12 12 0 0 0 0 $0.00
Records of operating conditions exceeding last performance test 1 8 8 136 1,088 54 109 $157,770.34
Records of startup, shutdown, malfunction, etc. 0.25 5 1.25 136 170 8.5 17 $24,651.62
Subtotal for Recordkeeping Requirements



1,447 $182,422
TOTAL LABOR BURDEN AND COST (rounded) e



2,540 $320,000
TOTAL CAPITAL AND O&M COST (rounded) e






$184,000
GRAND TOTAL (rounded) e






$504,000









Assumptions:







a Assume no new affected sources per year subject to subpart NNN and not the HON, and 136 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: Managerial $163.17 ($77.70 + 110%); Technical $130.28 ($62.04 + 110%); and Clerical $65.71 ($31.29 + 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2022, “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 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-8

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












$130.28 $163.17 $65.71
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) b
1. Applications N/A






2. Survey and Studies N/A






3. Reporting requirements







A. Familiarize with regulatory requirements c 1 1 1 74 74 3.7 7.4 $10,730.70
B. Required activities







Initial performance test report 60 1 60 0 0 0 0 $0.00
Repeat performance test report d 60 1 60 0 0 0 0 $0.00
C. Write report







Notification of construction/modification 2 1 2 0 0 0 0 $0.00
Notification of actual startup 1 1 1 0 0 0 0 $0.00
Notification of initial/repeat performance test 2 1 2 0 0 0 0 $0.00
Semiannual report 3 2 6 74 444 22 44 $64,384.22
Subtotal for Reporting Requirements



596 $75,115
4. Recordkeeping requirements







Records of operating parameters for control devices 1 12 12 0 0 0 0 $0.00
Records of operating conditions exceeding last performance test 1 8 8 74 592 30 59 $85,845.62
Records of startup, shutdown, malfunction, etc. 0.25 5 1.25 74 92.5 5 9 $13,413.38
Subtotal for Recordkeeping Requirements



787 $99,259
TOTAL LABOR BURDEN AND COST (rounded) e



1,380 $174,000
TOTAL CAPITAL AND O&M COST (rounded) e






$37,000
GRAND TOTAL (rounded) e






$211,000









Assumptions:







a Assume no new affected sources per year subject to subpart RRR and not the HON, and 74 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: Managerial $163.17 ($77.70 + 110%); Technical $130.28 ($62.04 + 110%); and Clerical $65.71 ($31.29 + 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2022, “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 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 33: Table G-9

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












$130.28 $163.17 $65.71
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) 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 $7,831
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 $4,785.31
Marine vessels 80 1 80 66 5,280 264 528 $765,650.16
Closed vent leak inspection 8 1 8 54 432 21.6 43.2 $62,644.10
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 $125,288.21
Subtotal for Reporting Requirements



7,662 $966,198
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 $610,780.01
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 $610,780
TOTAL LABOR BURDEN AND COST (rounded) e



12,500 $1,580,000
TOTAL CAPITAL AND O&M COST (rounded) e






$0
GRAND TOTAL (rounded) e






$1,580,000









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: Managerial $163.17 ($77.70 + 110%); Technical $130.28 ($62.04 + 110%); and Clerical $65.71 ($31.29 + 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2022, “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 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 34: Table G-10

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












$130.28 $163.17 $65.71
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) 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 $580.04
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 $4,640.30
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 $2,320.15
Supplemental delay report e 2 1 2 0.1 0.2 0.01 0.02 $23.20
Quarterly emission report f None expected






Subtotal for Reporting Requirements



60 $7,564
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 $1,160.08
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 $8,460
TOTAL CAPITAL AND O&M COST (rounded) g






$0
GRAND TOTAL (rounded) g






$8,460









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: Managerial $163.17 ($77.70 + 110%); Technical $130.28 ($62.04 + 110%); and Clerical $65.71 ($31.29 + 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2022, “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 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 35: Table G-11

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












$130.28 $163.17 $65.71
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year
(C=AxB)
Respondents per year a Technical hours per year
(E=CxD)
Management hours per year
(F=Ex0.05)
Clerical hours per year
(G=Ex0.1)
Total cost per year ($) 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 $9,715.64
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 $582,938.19
Subtotal for Reporting Requirements



4,700 $592,654
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 $435.03
Record of operation, parameters, and emissions 0.1 365 36.5 67 2,446 122 245 $354,620.73
Record of leaks detected 0.4 52 20.8 67 1,394 70 139 $202,085.24
F. Train personnel N/A






G. Audits N/A






Subtotal for Recordkeeping Requirements



4,418 $557,141
TOTAL LABOR BURDEN AND COST (rounded) e



9,120 $1,150,000
TOTAL CAPITAL AND O&M COST (rounded) e






$0
GRAND TOTAL (rounded) e






$1,150,000









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: Managerial $163.17 ($77.70 + 110%); Technical $130.28 ($62.04 + 110%); and Clerical $65.71 ($31.29 + 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2022, “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 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 36: Table G-12

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












$130.28 $163.17 $65.71
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Average hours per activity a Number of activities per year per respondent Technical hours per year per respondent Estimated number of New Respondents b Estimated technical hours per year
(E=CxD)
Estimated managerial hours per year
(F=Ex0.05)
Estimated clerical hours per year
(G=Ex0.1)
Total cost per year ($) c
1. Familiarize with regulatory requirements 2.69 93 250 0.67 167 8 17 $24,168.25
2. Plan activities 3.82 93 355 0.67 237 12 24 $34,318.92
3. Training 3.47 38 132 0.67 88 4 9 $12,760.84
4. Creation, testing, research, and development 2.4 1,778 4,266 0.67 2,844 142 284 $412,407.02
5. Gather information, monitor/inspect 1.4 2,102 2,943 0.67 1,962 98 196 $284,508.64
6. Process/compile and review 0.8 50 40 0.67 26.67 1 3 $3,866.92
7. Complete reports 11.37 49 557 0.67 371 19 37 $53,846.86
8. Record/disclose 9.98 49 489 0.67 326 16 33 $47,273.10
9. Store/file 5.18 51 264 0.67 176 9 18 $25,521.67
TOTAL LABOR BURDEN AND COST (rounded) d



7,100 $900,000
TOTAL CAPITAL AND O&M COST (rounded) d






See Table G-13
GRAND TOTAL (rounded) d






$900,000









Assumptions:







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







b We assume the number of new respondents will be 0.67 per year, or 1 in the three-year period of this ICR.







c This ICR uses the following labor rates: Managerial $163.17 ($77.70 + 110%); Technical $130.28 ($62.04 + 110%); and Clerical $65.71 ($31.29 + 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2022, “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.
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 37: Table G-13

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












$130.28 $163.17 $65.71
Burden item (A) (B) (C) (D) (E) (F) (G) (H)
Average hours per activity a Number of activities per year per respondent a Technical hours per year per respondent a, b Technical hours per year per respondent for wastewater a, c Estimated technical hours per year
(E=Cx189+Dx21)
Estimated managerial hours per year
(F=Ex0.05)
Estimated clerical hours per year
(G=Ex0.1)
Total cost per year ($) d
1. Familiarize with regulatory requirements 3.61 23 69 14 13,356 668 1,336 $1,936,771.05
2. Plan activities 6.08 13 61 18 11,926 596 1,193 $1,729,368.80
3. Training 5.25 4 17 4 3,302 165 330 $478,855.20
4. Creation, testing, research, and development 17.85 99 1,617 150 309,253 15,463 30,925 $44,844,637.40
5. Gather information, monitor/inspect 2.5 677 1,693 0 320,485 16,024 32,048 $46,473,355.11
6. Process/compile and review 20 1 20 0 3,786 189 379 $549,005.97
7. Complete reports 81.2 5 388 18 73,827 3,691 7,383 $10,705,616.36
8. Record/disclose 17.46 26 442 12 83,923 4,196 8,392 $12,169,632.27
9. Store/file 6.77 35 222 15 42,340 2,117 4,234 $6,139,716.73
TOTAL LABOR BURDEN AND COST (rounded) e



992,000 $125,000,000
TOTAL CAPITAL AND O&M COST (rounded) e






$58,000,000
GRAND TOTAL (rounded) e






$183,000,000









Assumptions:







a Average Hours per Activity (A) is back-calculated: (A) = ((C) + (D))/(B).
b There are 189 existing sources out of the 210 total that will continue to comply with the HON.
c The 21 facilities complying with the CAR will still be required to comply with HON requirements for wastewater.
d This ICR uses the following labor rates: Managerial $163.17 ($77.70 + 110%); Technical $130.28 ($62.04 + 110%); and Clerical $65.71 ($31.29 + 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2022, “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.
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 38: 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 0 $0 $1,350 218 $293,659
Subtotal $294,000
NSPS VV $0 0 $0 $0 170 $0
Subtotal $0
NSPS VVa $1,400 0 $0 $0 75 $0
Subtotal $0
NSPS DDD $30,000 5 $150,000 $7,000 93 $651,000
Subtotal $801,000
NSPS III $13,500 0 $0 $1,350 40 $54,000
Subtotal $54,000
NSPS NNN $13,500 0 $0 $1,350 136 $183,600
Subtotal $184,000
NSPS RRR $25,000 0 $0 $500 74 $37,000
Subtotal $37,000
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 0.67 $16,667 $275,000 211 $58,025,000
Subtotal $58,000,000
NESHAP H b $1,400 0.67 $7,000 $0 0 $0
Subtotal $7,000
NESHAP I $0 0 $0 $0 0 $0
Subtotal $0
CAR $0 0 $0 $275,000 21 $5,784,167
Subtotal $5,780,000
CAR Revisions $0 0 $0 $0 6 $0
Subtotal $0
Total for CAR and Referencing Subparts (rounded) c $65,200,000







a We assume that 5% of new respondents use a CVS as control, and that 5% of all existing storage tanks use a CVS as control. (385 existing respondents x 11.3 tanks per respondent x 5% tanks with CVS = 218, rounded)
b We assume there will be one new respondent over the three-year period of this ICR (average of 0.67 new respondents per year) and that the new respondent will perform LDAR services in-house and will purchase 5 units to support the program. The total annual capital/startup cost is 5 units x $1,400 = $7,000.
c Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.






Sheet 39: Labor

Labor Rates




Private
Technical Managerial Clerical
$130.28 $163.17 $65.71
b This ICR uses the following labor rates: Managerial $163.17 ($77.70 + 110%); Technical $130.28 ($62.04 + 110%); and Clerical $65.71 ($31.29 + 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2022, “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.



Agency
Technical Managerial Clerical
$54.51 $73.46 $29.50
b This cost is based on the average hourly labor rate as follows: Managerial $73.46 (GS-13, Step 5, $45.91 + 60%); Technical $54.51 (GS-12, Step 1, $34.07 + 60%); and Clerical $29.50 (GS-6, Step 3, $18.44 + 60%). This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. These rates are from the Office of Personnel Management (OPM), 2023 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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