| Table 1: Annual Respondent Burden and Cost – major source NESHAP for Gasoline Distribution (40 CFR Part 63, Subpart R) (Proposed Amendments) |
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Salaries taken for NAICS 324000 - Petroleum and Coal Products Manufacturing |
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76.78 |
146.2 |
50.48 |
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|
https://www.bls.gov/oes/current/naics3_324000.htm |
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| Burden item |
(A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
(H) |
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| Person hours per occurrence |
No. of occurrences per respondent per year |
Person hours per respondent per year |
Respondents per year a |
Technical person- hours per year |
Management person hours per year |
Clerical person hours per year |
Total Cost per year, ($) b |
|
Occupation Code |
Title |
Mean Hourly Rate |
110% OH and benefits |
Estimated Total Pay with Benefits |
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|
(C=AxB) |
|
(E=CxD) |
(F=Ex0.05) |
(G=Ex0.1) |
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|
11-0000 |
Mgmt Occup |
69.62 |
76.58 |
146.202 |
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|
| 1. Applications |
N/A |
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|
|
|
17-2081 |
Envir Engr |
54.64 |
60.10 |
114.744 |
|
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| 2. Surveys and studies |
N/A |
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|
|
|
49-9000 |
Maintenance/Inspections |
32.04 |
35.24 |
67.284 |
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| 3. Reporting requirements |
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|
43-0000 |
Office and Admin Support |
24.04 |
26.44 |
50.484 |
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| a. Familiarize with regulatory requirements c |
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Technical |
36.56 |
40.216 |
76.776 |
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| i. Bulk gasoline terminals |
8 |
1 |
8 |
97 |
776 |
38.8 |
77.6 |
$69,171 |
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|
|
|
|
| ii. Pipeline breakout stations |
4 |
1 |
4 |
8 |
32 |
1.6 |
3.2 |
$2,852 |
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|
Total Facilities |
Year 1 |
Year 2 |
Year 3 |
Average |
|
| b. Required activities d |
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Bulk gasoline terminal |
195 |
0 |
97.5 |
195 |
97 |
|
| i. Equipment leaks monitoringe |
0 |
2 |
0 |
105 |
0 |
0 |
0 |
$0 |
|
Bulk gasoline plant |
0 |
0 |
0 |
0 |
0 |
|
| ii. LEL monitoring |
0.75 |
1 |
0.75 |
405 |
303.75 |
15.1875 |
30.375 |
$27,076 |
|
Pipeline pumping station |
0 |
0 |
0 |
0 |
0 |
|
| iii. Performance tests f |
8 |
0.2 |
1.6 |
0 |
0 |
0 |
0 |
$0 |
|
Pipeline breakout station |
15 |
0 |
7.5 |
15 |
8 |
|
| iv. Performance evaluations g |
8 |
1 |
8 |
97 |
776 |
38.8 |
77.6 |
$69,171 |
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|
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| v. CEMS daily calibration checks g |
0.2 |
365 |
73 |
97 |
7081 |
354.05 |
708.1 |
$631,186 |
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| c. Write report |
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| i. Notification of compliance status |
1 |
1 |
1 |
105 |
105 |
5.25 |
10.5 |
$9,359 |
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| ii. Semiannual compliance reports for bulk gasoline terminals h |
5 |
2 |
10 |
0 |
0 |
0 |
0 |
$0 |
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| iii. Semiannual compliance reports for pipeline breakout stations h |
2.5 |
2 |
5 |
0 |
0 |
0 |
0 |
$0 |
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| iv. Notification of performance test |
1 |
0.2 |
0.2 |
0 |
0 |
0 |
0 |
$0 |
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| v. Report of performance test |
8 |
0.2 |
1.6 |
0 |
0 |
0 |
0 |
$0 |
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| vi. Notification of performance evaluation |
1 |
1 |
1 |
97 |
97 |
4.85 |
9.7 |
$8,646 |
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| vii. Report of performance evaluation |
8 |
1 |
8 |
97 |
776 |
38.8 |
77.6 |
$69,171 |
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| viii. Continuous Emissions Monitoring System (CEMS) QA plan |
40 |
0.33 |
13.33 |
195 |
2600 |
130 |
260 |
$231,759 |
|
Model Plant |
Number of IFR Tanks |
Total |
Year 1 |
Year 2 |
Year 3 |
Average |
| Subtotal for Reporting Requirements |
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|
12,547 |
627 |
1,255 |
$1,118,392 |
|
MP2 |
|
0 |
0 |
0 |
0 |
0 |
| 4. Recordkeeping Requirements |
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MP3 |
2 |
6 |
0 |
3 |
6 |
3 |
| a. Familiarize with regulatory requirements |
See 3A |
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MP3 |
3 |
33 |
0 |
16.5 |
33 |
16.5 |
| b. Plan activities |
3 |
1 |
3 |
105 |
315 |
15.75 |
31.5 |
$28,078 |
|
MP4 |
3 |
15 |
0 |
7.5 |
15 |
7.5 |
| c. Implement activities |
6 |
1 |
6 |
105 |
630 |
31.5 |
63 |
$56,157 |
|
MP4 |
4 |
63 |
0 |
31.5 |
63 |
31.5 |
| d. Develop record system |
1 |
1 |
1 |
105 |
105 |
5.25 |
10.5 |
$9,359 |
|
MP5 |
4 |
20 |
0 |
10 |
20 |
10 |
| e. Time to enter information |
0.5 |
2 |
1 |
105 |
105 |
5.25 |
10.5 |
$9,359 |
|
MP5 |
5 |
58 |
0 |
29 |
58 |
29 |
| f. Time to train personnel |
2 |
1 |
2 |
105 |
210 |
10.5 |
21 |
$18,719 |
|
MP4a |
3 |
2 |
0 |
1 |
2 |
1 |
| g. Time to adjust existing ways to comply with previously applicable requirements |
2 |
1 |
2 |
105 |
210 |
10.5 |
21 |
$18,719 |
|
MP4a |
4 |
2 |
0 |
1 |
2 |
1 |
| h. Time to transmit information |
0.25 |
2 |
0.5 |
105 |
52.5 |
2.625 |
5.25 |
$4,680 |
|
MP4b |
4 |
2 |
0 |
1 |
2 |
1 |
| Subtotal for Recordkeeping Requirements |
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1,627.5 |
81.4 |
162.8 |
$145,072 |
|
MP4b |
5 |
2 |
0 |
1 |
2 |
1 |
| TOTAL LABOR BURDEN AND COST |
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16,300 |
$1,263,464 |
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| Capital O&M Cost |
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$0 |
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| GRAND TOTAL |
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$1,263,464 |
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| Assumptions: |
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| a The average number of respondents per year over the first three years of this ICR. We assumed no facilities would report the first year, half the facilities would report the second year, and all facilities report the third year. |
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| b This ICR uses the following labor rates from the United States Department of Labor, Bureau of Labor Statistics, May 2020, mean labor rates for Petroleum and Coal Products Manufacturing (NAICS 324000) for Management Occupations (11-0000), Environmental Engineer (17-2081) and Office and Administrative Support (43-0000) . The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry. Fully burdened hourly rates are: $146.20 for management; $76.78 for technical; and $50.48 for clerical. |
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| c We have assumed that all respondents will have to familiarize with regulatory requirements each year. |
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| d We have assumed that existing respondents are in compliance with the initial rule requirements. |
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| e Equipment leaks monitoring was assumed to be performed by an external contractor and these costs were included in the costs of equipment leak monitoring programs. |
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| f Performance tests only required for vapor combustors. |
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| g Performance evaluations and CEMS calibrations only required for vapor recovery systems. |
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| h Respondents are already subject to semiannual compliance reporting. |
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| (A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
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| Monitoring Device |
Capital/Startup Cost for One Respondent |
Number of New Respondents |
Total Capital/Startup Cost, (B x C) |
Annual O&M Costs for One Respondent |
Number of Respondents with O&M |
Total O&M,
(E x F) |
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| LEL monitor |
$750 |
0 |
$0 |
$100 |
0 |
$0 |
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| VOC CEM |
$100,000 |
0 |
$0 |
$10,000 |
0 |
$0 |
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| Total |
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$0 |
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$0 |
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Agency Worker Rates |
Labor Rates, $/hr a |
60% Overhead |
Total, $/hr |
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Managerial (GS-13, step 5) |
$42.73 |
$25.64 |
$68.37 |
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| Table 2: Average Annual EPA Burden and Cost – NESHAP for Gasoline Distribution (40 CFR Part 63, Subpart R) (Proposed Amendments) |
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Technical (GS-12, step 1) |
$31.70 |
$19.02 |
$50.72 |
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2019: |
$50.72 |
$68.37 |
$27.46 |
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Clerical (GS-6, step 3) |
$17.16 |
$10.30 |
$27.46 |
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| Activity |
(A) EPA person-hours per occurrence |
(B) No. of occurrences per plant per year |
(C) EPA person hours per plant per year (AxB) |
(D) Plants per year a |
(E) Technical person-hours per year (CxD) |
(F) Management person-hours per year (Ex0.05) |
(G) Clerical person-hours per year (Ex0.1) |
(H) Cost, $ b |
|
a https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2020/GS_h.pdf |
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| Report review |
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Effective January 2020 |
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| Notification of applicability c |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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| Notification of performance test d |
1 |
0.2 |
0.2 |
0 |
0 |
0 |
0 |
$0 |
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| Notification of performance evaluation e |
1 |
1 |
1 |
97 |
97 |
5 |
10 |
$5,518 |
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| CEMS QA plan c |
2 |
1 |
2 |
195 |
390 |
20 |
39 |
$22,185 |
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| Notification of compliance status c |
2 |
1 |
2 |
105 |
210 |
11 |
21 |
$11,946 |
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| Performance test report d |
2 |
0.2 |
0.4 |
0 |
0 |
0 |
0 |
$0 |
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| Performance evaluation report e |
2 |
1 |
2 |
97 |
194 |
10 |
19 |
$11,035 |
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| Semiannual compliance reports f |
2 |
2 |
4 |
0 |
0 |
0 |
0 |
$0 |
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| TOTAL BURDEN AND COST |
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1,025 |
$50,684 |
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| Assumptions: |
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| a We have assumed that the average number of respondents that will be subject to this rule will be 105. There will be no new facilities projected during the next three years of this ICR. |
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| b This cost is based on the following 2020 labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: $68.37 Managerial rate (GS-13, Step 5), $50.72 Technical rate (GS-12, Step 1), and $27.46 Clerical rate (GS-6, Step 3). These rates are calculated from the hourly rates included in the Office of Personnel Management (OPM) 2020 General Schedule which excludes locality rates of pay; the rates have been increased by 60 percent to account for benefit packages available to government employees. |
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| c We have assumed that existing respondents are in compliance with the initial rule requirements. New respondents would have to comply with the initial rule requirements including notification and performance test for add-on control devices. |
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| d Performance tests only required for vapor combustors. |
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| e Performance evaluations only required for vapor recovery systems. |
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| f Respondents are already subject to semiannual compliance reporting. |
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| Information Collection Activity |
Number of Respondents |
Number of Responses |
Number of Existing Respondents That Keep Records But Do Not Submit Reports |
Total Annual Responses |
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E=(BxC)+D |
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| Notification of compliance status |
105 |
1 |
0 |
105 |
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| Semiannual compliance reports |
0 |
2 |
0 |
0 |
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| Notification of performance test |
0 |
0.2 |
0 |
0 |
|
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| Notification of performance evaluation |
97 |
1 |
0 |
97 |
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| Performance test |
0 |
0.2 |
0 |
0 |
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| Performance evaluation |
97 |
1 |
0 |
97 |
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Total |
299 |
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Averge response burden |
54.52 |
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| Table 1: Annual Respondent Burden and Cost – area source NESHAP for Gasoline Distribution (40 CFR Part 63, Subpart BBBBBB) (Proposed Amendments) |
|
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|
|
|
|
|
|
|
Salaries taken for NAICS 324000 - Petroleum and Coal Products Manufacturing |
|
|
|
|
|
|
|
|
|
|
76.78 |
146.2 |
50.48 |
|
|
|
|
https://www.bls.gov/oes/current/naics3_324000.htm |
|
|
|
|
| Burden item |
(A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
(H) |
|
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|
|
|
|
|
|
| Person hours per occurrence |
No. of occurrences per respondent per year |
Person hours per respondent per year |
Respondents per year a |
Technical person- hours per year |
Management person hours per year |
Clerical person hours per year |
Total Cost per year, ($) b |
|
Occupation Code |
Title |
Mean Hourly Rate |
110% OH and benefits |
Estimated Total Pay with Benefits |
|
|
|
|
(C=AxB) |
|
(E=CxD) |
(F=Ex0.05) |
(G=Ex0.1) |
|
|
11-0000 |
Mgmt Occup |
69.62 |
76.58 |
146.202 |
|
|
| 1. Applications |
N/A |
|
|
|
|
|
|
|
|
17-2081 |
Envir Engr |
54.64 |
60.10 |
114.744 |
|
|
| 2. Surveys and studies |
N/A |
|
|
|
|
|
|
|
|
49-9000 |
Maintenance/Inspections |
32.04 |
35.24 |
67.284 |
|
|
| 3. Reporting requirements |
|
|
|
|
|
|
|
|
|
43-0000 |
Office and Admin Support |
24.04 |
26.44 |
50.484 |
|
|
| a. Familiarize with regulatory requirements c |
|
|
|
|
|
|
|
|
|
|
Technical |
36.56 |
40.216 |
76.776 |
|
|
| i. Large bulk gasoline terminals |
8 |
1 |
8 |
116 |
928 |
46.4 |
92.8 |
$82,720 |
|
|
|
|
|
|
|
|
| ii. Small bulk gasoline terminals, bulk gasoline plants, pipeline pumping stations, and pipeline breakout stations |
4 |
1 |
4 |
4516 |
18064 |
903.2 |
1806.4 |
$1,610,189 |
|
|
Total Facilities |
Year 1 |
Year 2 |
Year 3 |
Average |
|
| b. Required activities d |
|
|
|
|
|
|
|
|
|
Bulk gasoline terminal |
1,090 |
0 |
545 |
1,090 |
545 |
|
| i. Equipment leaks monitoringe |
0 |
1 |
0 |
4632 |
0 |
0 |
0 |
$0 |
|
Bulk gasoline plant |
5,913 |
0 |
2956.5 |
5,913 |
2957 |
|
| ii. Performance tests f |
8 |
1 |
8 |
85 |
680 |
34 |
68 |
$60,614 |
|
Pipeline pumping station |
1,800 |
0 |
900 |
1,800 |
900 |
|
| iii. Performance evaluations g |
8 |
0.2 |
1.6 |
27 |
43.2 |
2.16 |
4.32 |
$3,851 |
|
Pipeline breakout station |
460 |
0 |
230 |
460 |
230 |
|
| iv. CEMS daily calibration checks g |
0.2 |
365 |
73 |
27 |
1971 |
98.55 |
197.1 |
$175,691 |
|
|
|
|
|
|
|
|
| v. Flare sampling |
|
|
|
|
|
|
|
|
|
|
Total Facilities |
Year 1 |
Year 2 |
Year 3 |
Average |
|
| Sample collection |
0.5 |
14 |
7 |
4 |
28 |
1.4 |
2.8 |
$2,496 |
|
Bulk gasoline terminal - Large - VCU |
170 |
0 |
85 |
170 |
85 |
|
| Analysis and reporting |
8 |
1 |
8 |
4 |
32 |
1.6 |
3.2 |
$2,852 |
|
Bulk gasoline terminal - Large - VCU - flare sampling |
136 |
0 |
68 |
136 |
68 |
|
| vi. VCU sampling |
|
|
|
|
|
|
|
|
|
Bulk gasoline terminal - Large - VCU - temperature |
34 |
0 |
17 |
34 |
17 |
|
| Sample collection |
0.5 |
14 |
7 |
68 |
476 |
23.8 |
47.6 |
$42,430 |
|
Bulk gasoline terminal - Large - VRU |
54 |
0 |
27 |
54 |
27 |
|
| Analysis and reporting |
8 |
1 |
8 |
68 |
544 |
27.2 |
54.4 |
$48,491 |
|
Bulk gasoline terminal - Large - flare |
8 |
0 |
4 |
8 |
4 |
|
| vii. LEL monitoring |
0.75 |
1 |
0.75 |
2642 |
1981.5 |
99.075 |
198.15 |
$176,627 |
|
Bulk gasoline terminal - Large |
232 |
0 |
116 |
232 |
116 |
|
| c. Write report |
|
|
|
|
|
|
|
|
|
Bulk gasoline terminal - Small |
858 |
0 |
429 |
858 |
429 |
|
| i. Notification of compliance status |
1 |
1 |
1 |
3073 |
3073 |
153.65 |
307.3 |
$273,921 |
|
|
|
|
|
|
|
|
| ii. Semiannual compliance reports - large bulk gasoline terminals h |
5 |
2 |
10 |
0 |
0 |
0 |
0 |
$0 |
|
Model Plant |
Number of IFR Tanks |
Total |
Year 1 |
Year 2 |
Year 3 |
Average |
| iii. Semiannual compliance reports - small bulk gasoline terminals, bulk gasoline plants, pipeline pumping stations, and pipeline breakout stations h |
2.5 |
2 |
5 |
0 |
0 |
0 |
0 |
$0 |
|
MP2 |
2 |
87 |
0 |
43.5 |
87 |
43.5 |
| iv. Notification of performance test |
1 |
0.2 |
0.2 |
85 |
17 |
0.85 |
1.7 |
$1,515 |
|
MP2 |
3 |
493 |
0 |
246.5 |
493 |
246.5 |
| v. Report of performance test |
8 |
0.2 |
1.6 |
85 |
136 |
6.8 |
13.6 |
$12,123 |
|
MP3 |
2 |
43 |
0 |
21.5 |
43 |
21.5 |
| vi. Notification of performance evaluation |
1 |
1 |
1 |
27 |
27 |
1.35 |
2.7 |
$2,407 |
|
MP3 |
3 |
235 |
0 |
117.5 |
235 |
117.5 |
| vii. Report of performance evaluation |
8 |
1 |
8 |
27 |
216 |
10.8 |
21.6 |
$19,254 |
|
MP4 |
3 |
49 |
0 |
24.5 |
49 |
24.5 |
| viii. Continuous Emissions Monitoring System (CEMS) QA plan |
40 |
0.33 |
13.33 |
54 |
720 |
36 |
72 |
$64,179 |
|
MP4 |
4 |
167 |
0 |
83.5 |
167 |
83.5 |
| Subtotal for Reporting Requirements |
|
|
|
|
28,937 |
1,447 |
2,894 |
$2,579,360 |
|
MP5 |
4 |
3 |
0 |
1.5 |
3 |
1.5 |
| 4. Recordkeeping Requirements |
|
|
|
|
|
|
|
|
|
MP5 |
5 |
13 |
0 |
6.5 |
13 |
6.5 |
| a. Familiarize with regulatory requirements |
See 3A |
|
|
|
|
|
|
|
|
MP4a |
3 |
50 |
0 |
25 |
50 |
25 |
| b. Plan activities |
1 |
1 |
1 |
4632 |
4632 |
231.6 |
463.2 |
$412,887 |
|
MP4a |
4 |
200 |
0 |
100 |
200 |
100 |
| c. Implement activities |
2 |
1 |
2 |
4632 |
9264 |
463.2 |
926.4 |
$825,774 |
|
MP4b |
4 |
53 |
0 |
26.5 |
53 |
26.5 |
| d. Develop record system |
1 |
1 |
1 |
4632 |
4632 |
231.6 |
463.2 |
$412,887 |
|
MP4b |
5 |
157 |
0 |
78.5 |
157 |
78.5 |
| e. Time to enter information |
0.5 |
2 |
1 |
4632 |
4632 |
231.6 |
463.2 |
$412,887 |
|
|
|
|
|
|
|
|
| f. Time to train personnel |
2 |
1 |
2 |
4632 |
9264 |
463.2 |
926.4 |
$825,774 |
|
|
|
|
|
|
|
|
| g. Time to adjust existing ways to comply with previously applicable requirements |
2 |
1 |
2 |
4632 |
9264 |
463.2 |
926.4 |
$825,774 |
|
|
|
|
|
|
|
|
| h. Time to transmit information |
0.25 |
2 |
0.5 |
4632 |
2316 |
115.8 |
231.6 |
$206,444 |
|
|
|
|
|
|
|
|
| Subtotal for Recordkeeping Requirements |
|
|
|
|
44,004 |
2,200 |
4,400 |
$3,922,429 |
|
|
|
|
|
|
|
|
| TOTAL LABOR BURDEN AND COST |
|
|
|
|
83,882 |
$6,501,788 |
|
|
|
|
|
|
|
|
| Capital O&M Cost |
|
|
|
|
|
|
|
$0 |
|
|
|
|
|
|
|
|
| GRAND TOTAL |
|
|
|
|
|
|
|
$6,501,788 |
|
|
|
|
|
|
|
|
| Assumptions: |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| a The average number of respondents per year over the first three years of this ICR. We assumed no facilities would report the first year, half the facilities would report the second year, and all facilities report the third year. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| b This ICR uses the following labor rates from the United States Department of Labor, Bureau of Labor Statistics, May 2020, mean labor rates for Petroleum and Coal Products Manufacturing (NAICS 324000) for Management Occupations (11-0000), Environmental Engineer (17-2081) and Office and Administrative Support (43-0000) . The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry. Fully burdened hourly rates are: $146.20 for management; $76.78 for technical; and $50.48 for clerical. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| c We have assumed that all respondents will have to familiarize with regulatory requirements each year. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| d We have assumed that existing respondents are in compliance with the initial rule requirements. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| e Equipment leaks monitoring was assumed to be performed by an external contractor and these costs were included in the costs of equipment leak monitoring programs. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| f Performance tests only required for vapor combustors. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| g Performance evaluations and CEMS calibrations only required for vapor recovery systems. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| h Respondents are already subject to semiannual compliance reporting. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| (A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
|
|
|
|
|
|
|
|
|
|
| Monitoring Device |
Capital/Startup Cost for One Respondent |
Number of New Respondents |
Total Capital/Startup Cost, (B x C) |
Annual O&M Costs for One Respondent |
Number of Respondents with O&M |
Total O&M,
(E x F) |
|
|
|
|
|
|
|
|
|
|
| LEL monitor |
$750 |
0 |
$0 |
$100 |
0 |
$0 |
|
|
|
|
|
|
|
|
|
|
| VOC CEM |
$100,000 |
0 |
$0 |
$10,000 |
0 |
$0 |
|
|
|
|
|
|
|
|
|
|
| Total |
|
|
$0 |
|
|
$0 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| Table 2: Average Annual EPA Burden and Cost – NESHAP for Gasoline Distribution (40 CFR Part 63, Subpart R) (Proposed Amendments) |
|
|
|
|
|
|
|
|
|
Agency Worker Rates |
Labor Rates, $/hr a |
60% Overhead |
Total, $/hr |
|
|
|
|
|
|
|
2019: |
$50.72 |
$68.37 |
$27.46 |
|
|
Managerial (GS-13, step 5) |
$42.73 |
$25.64 |
$68.37 |
|
|
|
| Activity |
(A) EPA person-hours per occurrence |
(B) No. of occurrences per plant per year |
(C) EPA person hours per plant per year (AxB) |
(D) Plants per year a |
(E) Technical person-hours per year (CxD) |
(F) Management person-hours per year (Ex0.05) |
(G) Clerical person-hours per year (Ex0.1) |
(H) Cost, $ b |
|
Technical (GS-12, step 1) |
$31.70 |
$19.02 |
$50.72 |
|
|
|
| Report review |
|
|
|
|
|
|
|
|
|
Clerical (GS-6, step 3) |
$17.16 |
$10.30 |
$27.46 |
|
|
|
| Notification of applicability c |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
|
a https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2020/GS_h.pdf |
|
|
|
|
|
|
| Notification of performance test d |
1 |
0.2 |
0.2 |
85 |
17 |
1 |
2 |
$967 |
|
Effective January 2020 |
|
|
|
|
|
|
| Notification of performance evaluation e |
1 |
1 |
1 |
27 |
27 |
1 |
3 |
$1,536 |
|
|
|
|
|
|
|
|
| CEMS QA plan c |
2 |
0.33 |
0.67 |
54 |
36 |
2 |
4 |
$2,048 |
|
|
|
|
|
|
|
|
| Notification of compliance status c |
4 |
1 |
2 |
3073 |
6,146 |
307 |
615 |
$349,609 |
|
|
|
|
|
|
|
|
| Performance test report d |
2 |
0.2 |
0.4 |
85 |
34 |
2 |
3 |
$1,934 |
|
|
|
|
|
|
|
|
| Performance evaluation report e |
2 |
1 |
2 |
27 |
54 |
3 |
5 |
$3,072 |
|
|
|
|
|
|
|
|
| Semiannual compliance reports f |
2 |
2 |
4 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
|
|
|
|
|
| TOTAL BURDEN AND COST |
|
|
|
|
7,261 |
$359,166 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| Assumptions: |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| a We have assumed that the average number of respondents that will be subject to this rule will be 4,632. There will be no new facilities projected during the next three years of this ICR. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| b This cost is based on the following 2020 labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: $68.37 Managerial rate (GS-13, Step 5), $50.72 Technical rate (GS-12, Step 1), and $27.46 Clerical rate (GS-6, Step 3). These rates are calculated from the hourly rates included in the Office of Personnel Management (OPM) 2020 General Schedule which excludes locality rates of pay; the rates have been increased by 60 percent to account for benefit packages available to government employees. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| c We have assumed that existing respondents are in compliance with the initial rule requirements. New respondents would have to comply with the initial rule requirements including notification and performance test for add-on control devices. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| d Performance tests only required for vapor combustors. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| e Performance evaluations only required for vapor recovery systems. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| f Respondents are already subject to semiannual compliance reporting. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| Information Collection Activity |
Number of Respondents |
Number of Responses |
Number of Existing Respondents That Keep Records But Do Not Submit Reports |
Total Annual Responses |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
E=(BxC)+D |
|
|
|
|
|
|
|
|
|
|
|
|
| Notification of compliance status |
3073 |
1 |
0 |
3073 |
|
|
|
|
|
|
|
|
|
|
|
|
| Semiannual compliance reports |
0 |
2 |
0 |
0 |
|
|
|
|
|
|
|
|
|
|
|
|
| Notification of performance test |
85 |
0.2 |
0 |
17 |
|
|
|
|
|
|
|
|
|
|
|
|
| Notification of performance evaluation |
27 |
1 |
0 |
27 |
|
|
|
|
|
|
|
|
|
|
|
|
| Performance test |
85 |
0.2 |
0 |
17 |
|
|
|
|
|
|
|
|
|
|
|
|
| Performance evaluation |
27 |
1 |
0 |
27 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Total |
3161 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Averge response burden |
26.54 |
|
|
|
|
|
|
|
|
|
|
|
|
| Table 1: Annual Respondent Burden and Cost – NSPS for Gasoline Distribution (40 CFR Part 60, Subpart XXa) (Proposed Rule) |
|
|
|
|
|
|
|
|
|
|
Salaries taken for NAICS 324000 - Petroleum and Coal Products Manufacturing |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
76.78 |
146.2 |
50.48 |
|
|
|
https://www.bls.gov/oes/current/naics3_324000.htm |
|
|
|
|
|
|
|
|
|
|
| Burden item |
(A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
(H) |
|
|
|
|
|
|
|
|
|
(A) |
(B) |
(C) |
(D) |
(E) |
| Person hours per occurrence |
No. of occurrences per respondent per year |
Person hours per respondent per year |
Respondents per year a |
Technical person- hours per year |
Management person hours per year |
Clerical person hours per year |
Total Cost per year, ($) b |
|
Occupation Code |
Title |
Mean Hourly Rate |
110% OH and benefits |
Estimated Total Pay with Benefits |
|
|
Year |
Number of New Respondents a |
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 Respondentsb |
|
|
(C=AxB) |
|
(E=CxD) |
(F=Ex0.05) |
(G=Ex0.1) |
|
|
11-0000 |
Mgmt Occup |
69.62 |
76.58 |
146.202 |
|
|
|
|
|
|
|
(E=A+B+C-D) |
| 1. Applications |
N/A |
|
|
|
|
|
|
|
|
17-2081 |
Envir Engr |
54.64 |
60.10 |
114.744 |
|
|
1 |
4 |
0 |
0 |
0 |
4 |
| 2. Surveys and studies |
N/A |
|
|
|
|
|
|
|
|
49-9000 |
Maintenance/Inspections |
32.04 |
35.24 |
67.284 |
|
|
2 |
4 |
4 |
0 |
0 |
8 |
| 3. Reporting requirements |
|
|
|
|
|
|
|
|
|
43-0000 |
Office and Admin Support |
24.04 |
26.44 |
50.484 |
|
|
3 |
4 |
8 |
0 |
0 |
12 |
| a. Familiarize with regulatory requirements c |
8 |
1 |
8 |
8 |
64 |
3.2 |
6.4 |
$5,705 |
|
|
Technical |
36.56 |
40.22 |
76.78 |
|
|
Average |
4 |
4 |
|
|
8 |
| b. Required activities |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| i. Equipment leaks monitoringd |
0 |
4 |
0 |
8 |
0 |
0 |
0 |
$0 |
|
|
Total Facilities (3rd year) |
Year 1 |
Year 2 |
Year 3 |
Average |
|
|
|
|
|
|
|
| ii. Performance tests e |
0 |
0.2 |
0 |
0 |
0 |
0 |
0 |
$0 |
|
Bulk gasoline terminal |
12 |
4 |
8 |
12 |
8 |
|
|
|
|
|
|
|
| iii. Performance evaluations f |
8 |
1 |
8 |
8 |
64 |
3.2 |
6.4 |
$5,705 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| iv. CEMS daily calibration checks f |
0.2 |
365 |
73 |
8 |
584 |
29.2 |
58.4 |
$52,057 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| c. Write report |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| i. Semiannual compliance reports |
5 |
2 |
10 |
8 |
80 |
4 |
8 |
$7,131 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| ii. Notification of startup g |
1 |
1 |
1 |
4 |
4 |
0.2 |
0.4 |
$357 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| iii. Notification of performance test e |
1 |
0.2 |
0.2 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| iv. Report of performance test e |
8 |
0.2 |
1.6 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| v. Notification of CEMS performance evaluation f |
1 |
1 |
1 |
8 |
8 |
0.4 |
0.8 |
$713 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| vi. Report of CEMS performance evaluation f |
8 |
1 |
8 |
8 |
64 |
3.2 |
6.4 |
$5,705 |
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|
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| Subtotal for Reporting Requirements |
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|
868 |
43 |
87 |
$77,372 |
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| 4. Recordkeeping Requirements |
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| a. Familiarize with regulatory requirements |
See 3A |
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| b. Plan activities |
3 |
1 |
3 |
8 |
24 |
1.2 |
2.4 |
$2,139 |
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| c. Implement activities |
6 |
1 |
6 |
8 |
48 |
2.4 |
4.8 |
$4,279 |
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| d. Develop record system |
1 |
1 |
1 |
8 |
8 |
0.4 |
0.8 |
$713 |
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| e. Time to enter information |
0.5 |
2 |
1 |
8 |
8 |
0.4 |
0.8 |
$713 |
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| f. Time to train personnel |
2 |
1 |
2 |
8 |
16 |
0.8 |
1.6 |
$1,426 |
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|
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| g. Time to transmit information |
0.25 |
2 |
0.5 |
8 |
4 |
0.2 |
0.4 |
$357 |
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| Subtotal for Recordkeeping Requirements |
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|
108 |
5 |
11 |
$9,627 |
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| TOTAL LABOR BURDEN AND COST |
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|
1,122 |
$86,999 |
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| Capital O&M Cost |
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|
$0 |
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| GRAND TOTAL |
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|
|
$86,999 |
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| Assumptions: |
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| a The average number of respondents per year over the first three years of this ICR. We assumed 4 facilities would report the first year, 8 facilities would report the second year, and 12 facilities report the third year (4 new, modified, or reconstructed facilities per year). |
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| b This ICR uses the following labor rates from the United States Department of Labor, Bureau of Labor Statistics, May 2020, mean labor rates for Petroleum and Coal Products Manufacturing (NAICS 324000) for Management Occupations (11-0000), Environmental Engineer (17-2081) and Office and Administrative Support (43-0000) . The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry. Fully burdened hourly rates are: $146.20 for management; $76.78 for technical; and $50.48 for clerical. |
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| c We have assumed that all respondents will have to familiarize with regulatory requirements each year. |
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| d Equipment leaks monitoring was assumed to be performed by an external contractor and these costs were included in the costs of equipment leak monitoring programs. |
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| e Performance tests only required for vapor combustors; assumed all new sources use vapor recovery systems. |
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| f Performance evaluations and CEMS calibrations only required for vapor recovery systems; assumed all new sources use vapor recovery systems. |
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| (A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
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| Monitoring Device |
Capital/Startup Cost for One Respondent |
Number of New Respondents |
Total Capital/Startup Cost, (B x C) |
Annual O&M Costs for One Respondent |
Number of Respondents with O&M |
Total O&M,
(E x F) |
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| VOC CEM |
$100,000 |
0 |
$0 |
$10,000 |
0 |
$0 |
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| Total |
|
|
$0 |
|
|
$0 |
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| Table 2: Average Annual EPA Burden and Cost – NSPS for Gasoline Distribution (40 CFR Part 60, Subpart XXa) (Proposed Rule) |
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2019: |
$50.72 |
$68.37 |
$27.46 |
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| Activity |
(A) EPA person-hours per occurrence |
(B) No. of occurrences per plant per year |
(C) EPA person hours per plant per year (AxB) |
(D) Plants per year a |
(E) Technical person-hours per year (CxD) |
(F) Management person-hours per year (Ex0.05) |
(G) Clerical person-hours per year (Ex0.1) |
(H) Cost, $ b |
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| Report review |
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| Notification of startup c |
0.5 |
1 |
0.5 |
4 |
2 |
0 |
0 |
$114 |
|
Agency Worker Rates |
Labor Rates, $/hr a |
60% Overhead |
Total, $/hr |
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| Notification of performance test d |
1 |
0.2 |
0.2 |
0 |
0 |
0 |
0 |
$0 |
|
Managerial (GS-13, step 5) |
$42.73 |
$25.64 |
$68.37 |
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| Notification of performance evaluation e |
1 |
1 |
1 |
8 |
8 |
0 |
1 |
$455 |
|
Technical (GS-12, step 1) |
$31.70 |
$19.02 |
$50.72 |
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| Performance test report d |
2 |
0.2 |
0.4 |
0 |
0 |
0 |
0 |
$0 |
|
Clerical (GS-6, step 3) |
$17.16 |
$10.30 |
$27.46 |
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| Performance evaluation report e |
2 |
1 |
2 |
8 |
16 |
1 |
2 |
$910 |
|
a https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2020/GS_h.pdf |
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| Semiannual compliance reports |
2 |
2 |
4 |
8 |
32 |
2 |
3 |
$1,820 |
|
Effective January 2020 |
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| TOTAL BURDEN AND COST |
|
|
|
|
67 |
$3,299 |
|
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| Assumptions: |
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| a We have assumed that the average number of respondents that will be subject to this rule will be 8, with four new, modified or reconstructed facilities added each year for the next three years of this ICR. |
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| b This cost is based on the following 2020 labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: $68.37 Managerial rate (GS-13, Step 5), $50.72 Technical rate (GS-12, Step 1), and $27.46 Clerical rate (GS-6, Step 3). These rates are calculated from the hourly rates included in the Office of Personnel Management (OPM) 2020 General Schedule which excludes locality rates of pay; the rates have been increased by 60 percent to account for benefit packages available to government employees. |
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| c Only new respondents would have to comply with the initial rule requirements including notifications. |
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| d Performance tests only required for vapor combustors; assumed all new sources use vapor recovery systems. |
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| e Performance evaluations only required for vapor recovery systems; assumed all new sources use vapor recovery systems. |
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| Information Collection Activity |
Number of Respondents |
Number of Responses |
Number of Existing Respondents That Keep Records But Do Not Submit Reports |
Total Annual Responses |
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|
E=(BxC)+D |
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| Semiannual compliance reports |
8 |
2 |
0 |
16 |
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| Notification of startup |
4 |
1 |
0 |
4 |
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|
| Notification of performance test |
0 |
0.2 |
0 |
0 |
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|
|
|
|
|
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|
|
| Notification of performance evaluation |
8 |
1 |
0 |
8 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
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|
|
| Performance test |
0 |
0.2 |
0 |
0 |
|
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|
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|
|
|
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|
|
|
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|
|
| Performance evaluation |
8 |
1 |
0 |
8 |
|
|
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|
Total |
36 |
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|
Averge response burden |
31.18 |
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