1625-0066_SS.c

1625-0066 (Formerly 2115-0595)

Supporting Statement
for
Vessel and Facility Response Plans (Domestic and Int’l), and
Additional Response Requirements for Prince William Sound, Alaska
A. Justification
1.

Circumstances that make the collection of information necessary.

Facility Response Plan (FRP): Section 4202 (a)(6) of the Oil Pollution Act of 1990 (OPA 90)
amended section 311(j) of the Federal Water Pollution Control Act (FWCPA). It requires the
owner or operator of a facility to prepare and submit “a plan for responding, to the maximum
extent practicable, to a worst case discharge, and to a substantial threat of such a discharge of oil
or hazardous substances.” This requirement applies to any offshore facility and to an onshore
facility that "because of its location, could reasonably be expected to cause substantial harm to
the environment by discharging into or on the navigable waters, adjoining shorelines, or the
exclusive economic zone." Under Title 33 CFR subpart H, § 154.1220 and § 154.1225 require
an owner or operator of a facility that handles animal fats and vegetable oils to modify the
facility response plans to incorporate average most probable discharge planning.
Vessel Response Plan (VRP): Section 4202 (a)(6) of the Oil Pollution Act of 1990 (OPA 90)
amended section 311(j) of the Federal Water Pollution Control Act (FWPCA). The plan requires
that vessels carrying oil in bulk as cargo and operating in waters subject to U.S. jurisdiction
prepare and submit a written response plan for a worst case discharge of oil or hazardous
substances.
Non Tank Vessel Response Plan (NTVRP): Section 701 of the Coast Guard and Maritime
Transportation Act of 2004 (Public Law 108-293) amended section 311 (a) and (j) of the
FWPCA. This plan requires that nontank vessels of 400 ITC gross tons and above which carry
oil as fuel for propulsion and operating in waters subject to U.S. jurisdiction prepare and submit
a written response plan for a worst case discharge.
Prince William Sound (PWS): Section 5005 of the Oil Pollution Act of 1990 (OPA 90)
establishes requirements for a tanker operating in PWS and loading cargo at the Trans Alaska
Pipeline System (TAPS), in addition to those required by section 4202(a)(5) of OPA 90. This
rule ensures that response plans provide for pre-positioned oil spill containment and removal
equipment, an oil spill removal organization, training of local residents in oil spill removal and
containment techniques, practice exercises, and periodic testing and certification of equipment.
Shipboard Oil Pollution Emergency Plan (SOPEP): The information collection requirements
described below are necessary to comply with the statute (33 USC 1901, et. seq.) This section
implements Regulation 26 of Annex I of MARPOL 73/78 for United States flag ships. It
requires every oil tanker of 150 gross tons and above and every ship other than an oil tanker of
400 gross tons and above to carry on board an approved SOPEP.
This information collection supports the following strategic goals:

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Department of Homeland Security
• Protection
• Recovery
Coast Guard
• Safety
• Protection of the Natural Resources
Prevention Directorate (G-M)
• Safety: Eliminate deaths, injuries, and property damage associated with commercial
maritime operations.
• Human and Natural Environment: Eliminate environmental damage associated with
maritime transportation and operations on and around the nation’s waterways.
2.

By whom, how, and for what purpose the Information is to be used.

FRP, VRP, and NTVRP: The purpose of OPA 90 is to reduce the number of oil and hazardous
substance spills and to minimize the impact of the oil and hazardous substance spills when they
do occur in U.S. waters. The requirements for preparation, submission, and approval of Vessel
Oil and Hazardous Substance Spill Response Plans (VRPs), Facility Oil and Hazardous
Substance Spill Response Plans (FRPs) and Nontank Vessel Response Plans (NTVRPs) are
central to the contingency planning elements of the Federal Water Pollution Control Act. The
VRP, FRP & NTVRP requirements are necessary to ensure that vessels entering U.S. waters and
certain facilities are adequately prepared to respond in the event of an incident involving the spill
of oil or a hazardous substance. Without the proposed requirements some operators may not
maintain the necessary internal resources (effective planning, training, drilling, etc.) or external
resources (adequate response capability) to meet one major intent of FWPCA to reduce the
consequences of an oil or hazardous substance spill when it occurs.
Submission of Response Plans to the U.S. Coast Guard for approval is considered to be the most
efficient way to ensure compliance and necessary for the Coast Guard to meet its obligations
under OPA 90/FWPCA.
PWS: The additional requirements in section 5005 of OPA 90, for trained personnel and prepositioned response equipment, reflect the particular environmental sensitivity of Prince William
Sound (PWS). Without these requirements for tankers operating in Prince William Sound and
loading cargo at TAPS, it is believed that sufficient response resources would not be available or
be properly maintained to clean up a future oil spill. Certification and testing of response
equipment will help ensure the readiness of this equipment for a future response.
SOPEP: The purpose of Regulation 26 to Annex I of MARPOL 73/78 is to improve response
capabilities and minimize the environmental impact of oil discharges from ships. Without the
requirements for "Shipboard Oil Pollution Emergency Plans,” there is a greater likelihood of a
vessel which is not prepared to handle an unauthorized discharge of oil having a spill and
causing a major environmental incident. The submission and approval of these plans ensures
that vessels have in place an appropriate plan that deals with such an occurrence.
3.

Consideration of the use of improved information technology.
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The information required is particular and sole to each vessel and facility. The plans are
generally submitted via regular mail. The Coast Guard does not have the capability of receiving
them electronically because each plan—due to file size and graphic elements—may require a
unique software package to be downloaded before a plan can be reviewed. Brief text-based
amendments to plans are accepted electronically. It is estimated that 10% of the correspondence
is done in this fashion.
4.

Efforts to identify duplication. Why similar information cannot be used.

FRP: The Coast Guard conducted a review of both State and Federal regulations to identify the
degree to which facilities affected by the Coast Guard information collection requirements would
have already prepared similar information in order to comply with existing regulations. At least
14 states have regulations requiring varying degrees of response planning. The extent of
duplication was estimated by evaluating the overlap of response plan requirements and affected
facilities between each State regulation and the Coast Guard requirements. For example, the
contingency planning requirements of New York State apply only to facilities with an oil storage
capacity of 400,000 gallons, which excludes a substantial portion of the Coast Guard regulated
facilities in the state.
In addition, State requirements do not generally cover all sections of the facility response plan
requirements stated by the Coast Guard, including certain statutorily mandated requirements.
Based on a review of the overlap in response plan requirements and facility coverage between
current state response planning requirements and the Coast Guard requirements, the extent of
overlap is not significant.
In addition to State facility response planning requirements, Environmental Protection Agency
(EPA) has facility response plan regulations. These response plan requirements affect certain
non-transportation-related facilities that have the potential to discharge oil into the navigable
waters or adjoining shorelines of the U.S. and meet certain storage capacity thresholds.
EPA's regulations do not apply to equipment or operations of onshore marine transportationrelated facilities that are subject to the authority and control of the Department of Transportation
(by delegation to the Coast Guard). However, certain businesses have both transportation-related
and non-transportation-related components, such as petroleum bulk terminals that have storage
tanks and transfer petroleum to and from vessels. These businesses may be subject to both the
Coast Guard's proposed regulation and EPA's proposed regulation. This analysis designates
these facilities as complexes.
To avoid duplicative paperwork burdens on complexes, the Coast Guard and EPA have been
working together very closely to ensure that their response plan requirements and response plan
formats are consistent. As a result of this effort, complexes will be able to comply with both
response plan requirements with a single response plan, thereby mitigating duplication of
paperwork related burdens. Where available, similar information from EPA will be used.
PWS: The information being required is unique. There is no known duplication of filing

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requirements with other Federal information collections.
NTVRP: The information required is unique. Section 701 of the Coast Guard and Maritime
Transportation Act of 2004 amended 33 U.S.C. 1321(j)(5)(a) and (j) requiring that nontank
vessel response plans be submitted consistent with other plans required by the Federal Water
Pollution Control Act.
SOPEP and VRP: The information required is unique. Regulation 26 of Annex I of MARPOL
73/78 requires specific response planning. These requirements work in conjunction with, and
not in duplication of, the Vessel Response Plan requirements discussed elsewhere in this
supporting statement.
5.

Methods to minimize the burden to small businesses if involved.

FRP: Although the Coast Guard regulation has certain reduced requirements for smaller
facilities, these are primarily not paperwork related. However, because of the nature of the
information collection requirements, the level of effort to prepare the facility response plan is
estimated to vary directly with the size and complexity of the facility. As a result, smaller
facilities are estimated to incur a lesser burden than larger facilities (i.e., the paperwork burden is
not constant across sizes and types of affected facilities).
Furthermore, in drafting OPA 90, it was clearly Congress' intent that certain small facilities be
subject to the same response planning requirements as large facilities. Specifically, in discussing
the selection of facilities that could cause "substantial harm" to the environment (i.e., those
subject to the information collection activities), the OPA Conference report states:
The criteria should not result in the selection of facilities based solely on the size or age of
storage tanks. Specifically, the selection criteria should not necessarily omit those smaller
facilities that are near major drinking water supplies or that are near environmentally sensitive
areas. H. Rep. No. 101-653, 101st Cong. 2nd Sess. 1990, p. 150.
VRP: Due to the nature of the industry, smaller entities tend to own smaller vessels, e.g., barges
rather than large tankers. The reporting requirements are less than those for larger vessels;
vessels have fewer personnel, carry less cargo, and require less response capability. Vessels that
carry oil as secondary cargo, i.e., fishing vessels, offshore supply vessels and towing vessels,
require a less comprehensive VRP and have reduced resubmission requirements. In addition,
there is a very small number of these vessels applicable to these requirements. Unmanned barge
owners or operators are required to maintain a corporate plan with a notification and emergency
procedures list on each barge.
NTVRP: The Federal Water Pollution Control Act (33 U.S.C. 1321(j)(5)) as amended by
Section 701 of the Coast Guard and Maritime Transportation Act of 2004 requires the same level
of information from vessels in order to receive interim operating approval.
PWS: The paperwork requirements for smaller vessels are less because they have fewer
personnel on board, carry less oil, and will require less response equipment than larger vessels.

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In addition, non-TAPS vessels (most of which are smaller) were eliminated from the
requirements.
SOPEP: The small business burden should be minimized as few small entities own ships of the
gross tonnage to which this regulation applies.
6.

Consequences to the Federal program if collection were done less frequently.

FRP, VRP, and NTVRP: The Coast Guard recognizes the need to minimize the burden of any
information collection to the extent permitted under the requirements of the Federal Water
Pollution Control Act as amended by OPA 90 and the Coast Guard and Maritime Transportation
Act of 2004. Section 4202(a)(6) of OPA 90 requires facilities and vessels to update the response
plan periodically, and resubmit for approval of each significant change. Under the regulation,
facilities and vessels would be required to: conduct an annual review of the response plan and
submit changes to the Coast Guard; or, if no changes are necessary, submit a letter stating that
the review has taken place.
The Coast Guard has determined that requiring facilities and vessels to review and update their
response plans less frequently than once a year would undermine the intent of the Federal Water
Pollution Control Act, which is to ensure that all facilities and vessels have an up-to-date plan at
all times. For example, contact lists of spill response personnel may require revision every year,
and possibly more frequently. Because the majority of information collection activities (in terms
of both hours and cost) would involve initial preparation of the response plan, reducing the
frequency of the annual information collection activities would not significantly reduce the
overall burden of the information collection activities required under these regulations.
PWS: Less frequent oversight and review of plans and equipment may result in inadequate
equipment and poorly trained personnel.
SOPEP: Because the plan must be used in an emergency, less frequent review and submission
could result in outdated information impeding a response.
7.

Explain any special circumstances that would cause the information collection to be
conducted in a manner inconsistent with guidelines.

The information collection activities discussed in this ICR comply with all Paperwork Reduction
Act regulatory guidelines except that facilities and vessels would be required to retain the
response plan beyond the three year period. The Coast Guard believes that the incremental
burden on facilities and vessels for maintaining the response plan beyond the three year period is
justified by the benefits of retaining an adequate and timely oil spill response capability. In
addition, it reduces the burden on industry.
8.

Consultation.

The regulations for this collection were developed using public notice and comments, and
followed the rules of the Administrative Procedure Act.

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9.

Explain any decision to provide any payment or gift to respondents.

There are no payments or gifts made to respondents.
10.

Describe any assurance of confidentiality provided to respondents.

All information collected complies with the Freedom of Information Act, the Privacy Act and
OMB Circular A-108. Confidentiality is promised, when requested, for information exempt
from the mandatory public disclosure requirements of Freedom of Information Act, or when the
information is a trade secret.
11.

Additional justification for any questions of a sensitive nature.

The information collection activities discussed in this document do not involve any sensitive
questions.
12.

Estimates of reporting and recordkeeping hour and cost burdens of the collection of
information.

12-1. FRP: This section presents the number of respondents and presents the burden and cost
estimates.
(a)

Number of Respondents

Based on information from the U.S. Coast Guard Office of Vessel Activities (G-PCV), 3,881
facilities are subject to the Coast Guard facility response plan requirements. It has been assumed
for the purposes of document that the number of facilities remains constant due to the mature
nature of the industry. However, facilities are sold and new ones are built as older ones are taken
out of service, there it has been assumed that 360 new facility response plans will be submitted
per year. This figure represents 10% of the affected population.
(b)

Summary of Paperwork Burdens and Cost

The paperwork requirements consist of the initial preparation and submission of the response
plan, annual submission of revisions to the Coast Guard as changes occur, and annual
recordkeeping activities. The burden and cost were estimated over a 5 year period. These are
described in more detail below.
Response Burden. The primary response burden in the first year is for facilities to prepare and
submit to the Coast Guard the facility response plan. In subsequent years, facilities would be
required to perform an annual review of their response plan and submit to the Coast Guard either
(1) any revisions made to the response plan, or (2) a letter indicating that the annual review was
conducted. In addition, facilities would be required to resubmit their response plans to the Coast
Guard every five years.

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Recordkeeping Burden. Recordkeeping activities include revising and maintaining an updated
response plan based on information collected primarily during the annual review. In addition,
facilities are required to maintain records of drills and training. Copies of the updated plan must
be maintained by the facility owner or operator and by the qualified individual.
Total Burden and Cost. The estimated annual burden and cost for FRPs is 93,720 hours at a cost
of $3,280,193. See FRP Table for details.
12-2. VRP: This section presents the number of respondents and presents the burden and cost
estimates.
(a)

Number of Respondents

Based on information from the U.S. Coast Guard Office of Vessel Activities (G-PCV), the office
responsible for reviewing and approving VRPs, there are approximately 798 VRPs covered by
this collection of information. There are 6,840 correspondence letters annually for plan revisions
Companies will approach the plan development requirement in different ways. Some companies
will develop the VRPs entirely in-house; some will contract out to consultants or use a
combination of consultant and in-house resources for plan development; while others may rely
on industry associations for core "generic" VRPs that are then modified to suit the particulars of
a vessel or company.
(b)

Summary of Paperwork Burdens and Cost

The paperwork requirements consist of the initial preparation and submission of the response
plan, annual review and submission of revisions to the Coast Guard as changes occur, annual
recordkeeping activities, and resubmit of the plan every 5 years. The burden and cost were
estimated over a 5-year period. These are described in more detail below.
Response Burden. The primary response burden, consists of the 1)initial preparation of the
vessel response plan; 2)submission of the plan to the U.S. Coast Guard for approval; 3)
submission of revisions or modifications to a response plan, as material changes occurs for the
vessel to prepare, and 4) submit to the Coast Guard the vessel response plan. In addition, the
plans are to be resubmitted every five years and the paperwork burden for the resubmission is
expected to be the same as for the annual review plus additional time for copying/mailing.
Recordkeeping Burden. Recordkeeping activities include revising and maintaining an updated
response plan based on information collected primarily during the annual review. In addition,
vessels are required to maintain records of drills and training. Copies of the updated plan must
be maintained by the vessels response planholder and by the qualified individual.
Total Burden and Cost. The estimated annual burden and cost for VRPs is 29,588 hours at a
cost of $2,719,440. See VRP Table for details.
12-3. NTVRP: This section presents the number of respondents and presents the burden and
cost estimates.

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(a)

Number of Respondents

Based on information from the U.S. Coast Guard Office of Vessel Activities (G-PCV), the office
responsible for reviewing and approving NTVRPs, there are approximately 2,000 NTVRPs
covered by this collection of information. There are 4,156 correspondence letters annually for
plan revisions Companies will approach the plan development requirement in different ways.
Some companies will develop the NTVRPs entirely in-house; some will contract out to
consultants or use a combination of consultant and in-house resources for plan development;
while others may rely on industry associations for core "generic" NTVRPs that are then modified
to suit the particulars of a vessel or company.
(b)

Summary of Paperwork Burdens and Cost

The paperwork requirements consist of the initial preparation and submission of the response
plan, annual review and submission of revisions to the Coast Guard as changes occur, annual
recordkeeping activities, and resubmit of the plan every 5 years. The burden and cost were
estimated over a 5-year period. These are described in more detail below.
Response Burden. The primary response burden, consists of the 1)initial preparation of the
vessel response plan; 2)submission of the plan to the U.S. Coast Guard for approval; 3)
submission of revisions or modifications to a response plan, as material changes occurs for the
vessel to prepare, and 4) submit to the Coast Guard the vessel response plan. In addition, the
plans are to be resubmitted every five years and the paperwork burden for the resubmission is
expected to be the same as for the annual review plus additional time for copying/mailing.
Recordkeeping Burden. Recordkeeping activities include revising and maintaining an updated
response plan based on information collected primarily during the annual review. In addition,
vessels are required to maintain records of drills and training. Copies of the updated plan must
be maintained by the vessels response planholder and by the qualified individual.
Total Burden and Cost. The estimated annual burden and cost for NTVRPs is 35,268 hours at a
cost of $2,926,800. See NTVRP Table for details.

12-4. PWS: There will be one spill response organization working in Prince William Sound. It
will serve the Trans Alaska Pipeline System (TAPS) traffic and includes large tankers receiving
oil at the Valdez terminal.
Burden to Industry
There are 600 total clerical hours (80 hrs for operational readiness + 120 hrs for drills + 400 hrs
for training) required for reporting and recordkeeping. Total clerical cost is $12,000 for
information collection for section 5005 of OPA 90 (600 hours x $20 clerical cost/hour).
There are 680 total technical hours (200 hrs for operational readiness + 480 hrs for drills)

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required for information collection. The total technical cost is $34,000 for information
collection for section 5005 of OPA 90 (680 hours x $50 technical cost/hour)
Total Burden and Cost. The estimated annual burden and cost for PWS requirements is 1,280
hours at a cost of $46,000. See PWS Table for details.
12-5. SOPEP: This section presents the number of respondents and presents the burden and
cost estimates.
(a)

Number of Respondents

Based on information from the U.S. Coast Guard Office of Vessel Activities (G-PCV), the office
responsible for reviewing and approving SOPEPs, there are approximately 2,794 SOPEPs
annually covered by this collection of information. The Coast Guard estimates 921 new SOPEP
get approved annually. There are 2,820 correspondence letters annually for plan revisions. It is
assumed that 2 new US flagged tank vessels will be built each year. Companies will approach
the plan development requirement in different ways. Some companies will develop the SOPEPs
entirely in-house; some will contract out to consultants or use a combination of consultant and
in-house resources for plan development; while others may rely on industry associations for core
"generic" SOPEPs that are then modified to suit the particulars of a vessel or company.
(b)

Summary of Paperwork Burdens and Cost

The paperwork requirements consist of initial preparation of the Shipboard Oil Pollution
Emergency Plan (SOPEP), submission of the plan to the U.S. Coast Guard for approval, and
submission of revisions or modifications to a plan as material changes occur. All vessels require
certification every year. US flagged tank vessels are assumed to be in compliance with the
MARPOL 73/78 by submitting their plans in conjunction with their VRPs, with a small
additional time increased. The Coast Guard estimates the cost of adding the MARPOL
requirements into the VRP to be 18 hours per plan. The burden and cost were estimated over a 5
year period.
Total Burden and Cost. The estimated annual burden and cost for SOPEP requirements is
60,703 hours at a cost of $2,731,635. See SOPEP Table for details.
12-6. Total Burden and Cost of submitting form CG-6083. The Coast Guard has created the
form “Application for Approval/Revision of Vessel Response Plans.” The purpose of the form is
to provide for an easier and clearer method to request a specific USCG review a submitted vessel
response plan or revision to a response plan. The Coast Guard estimates that approximately 50%
of submissions will voluntarily use this form. It will take approximately .16 hours to complete
form, therefore the total hours of burden will be about 16,400 (32,675 * .5) at a cost of $118,080
( 16,400 * ($45/hr * .16)). However, this burden is not added to the total, as use of the form
replaces the need to draft a letter explaining what action is requested.
12-7. Summary

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Total Number of Respondents. The number of respondents subject to the information
collection requirements is estimated to be a total of 9,834 in terms of response burden [(FRP:
3,881 +360) + (VRP: 798) + (NTVRP: 2,000) + (PWS: 1) + (SOPEP: 2,794)]
Total Number of Responses. The number of responses subject to the information collection
requirements is estimated to be a total of 32,675 [(FRP: 8,838 = 360 + 3,881 + 3,881 + 716) +
(VRP: 7,909 = 111 + 6,840 + 798 +160) + (NTVRP: 6,596 = 280 + 4,156 + 2,000 + 160)+
(PWS: 1) + (SOPEP: 9,331 = 921 + 2 + 2,820 +2,794 + 2,794)].
Total Respondent Hour Burden. The hour burden is estimated to total 220,559 hours [(FRP:
93,720) + (VRP: 29,588) + (NTVRP: 35,268) + (PWS: 1,280) + (SOPEP: 60,703)].
Total Respondent Cost Burden. The cost burden of collection on the respondents is expected
to total $11,704,068 [(FRP: $3,280,193) + (VRP: $2,719,440) + (NTVRP: $2,926,800)+ (PWS:
$46,000) + (SOPEP: $2,731,635)].
13.

Estimates of annualized capital and start-up costs.

There are no annualized capital and start-up costs.
14.

Estimates of annualized Federal government costs.

14-1 FRP
Based on Coast Guard estimates, about 18 full time equivalents are utilized annually for this
program to process, review, and approve facility response plans. Additional information-related
collection burdens also may be incurred to conduct inspections, oversee drills, and perform other
tasks to implement the program. The Coast Guard is expected to spend approximately 36,000
hours (18 billets x 250 work days x 8 hour work days) or $1,075,320, based on full-year salaries
of $59,740.
14-2 VRP, NTVRP, and SOPEP
Based on information from the Coast Guard’s Office of Vessel Activities (G-PCV) the cost to
the Federal government to administer the NTVRP, VRP and SOPEP program is approximately
$3,318,675 annually. To accomplish this, the Coast Guard utilizes a private support contract to
accomplish administrative and technical requirements.
14-3 PWS
It is estimated that this requirement would require 20% of the time of a lieutenant assigned to the
USCG Marine Safety Office in Valdez. Estimated at 400 hours annually.
Four hundred hours for a lieutenant at $51/hour will cost the Coast Guard $20,400 annually
($51 x 400 = $20,400).
Total Government Cost Burden. Therefore, annual costs to the Coast Guard are expected to
total $4,406,395 [(FRP: $1,075,320) + (VRP/NTVRP/SOPEP: $3,318,675) + (PWS: $12,400)].

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15.

Explain the reasons for the change in burden.

The change in burden is both a PROGRAM CHANGE and an ADJUSTMENT. The program
change is due to the addition of the new NTVRP collection. The adjustment is due to a change
in the vessel and facility populations and frequency of document submission.
16.

For collections of information whose results are planned to be published for statistical
use, outline plans for tabulation, statistical analysis and publication.

There are no plans to publish information for statistical use.
17.

Explain the reasons for seeking not to display the expiration date for OMB approval of
the information collection.

We are not seeking such approval. The OMB Number will appear on appropriate PRA
disclosure information.
18.

Explain each exception to the certification statement.

There are no exceptions to the certification statement.

B. Collection of Information Employing Statistical Methods
This information collection does not employ statistical methods.

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Table FRP
INDUSTRY REPORTING BURDEN/COSTS
INITIAL PLAN DEVELOPMENT
Number of
Facilities

Burden Hours
Per Facility

360

90

Total Burden
Hours

1

32,400 x$35/hr =

Cost

$

1,134,000

Subsequent Year Response Burden Estimates
Annual review

Number of
Facilities

Burden Hours
Per Facility

3,881

10

Total Burden
Hours

1

Cost

38,810 x $35/hr = $

1,358,350

ANNUAL RECORDKEEPING BURDEN
Number of
Facilities

Burden Hours
Per Facility

3,881

5

Total Burden
Hours

1

Cost

19,405 x $35/hr = $

679,175

FIFTH YEAR SUBMITTAL BURDEN
Number of
Facilities
3,881

Burden Hours
Per Facility
4

1

Total Burden
Hours

Cost

15,524 x 0.2
3,105 x $35/hr = $
Total Annual Cost
$

108,668
3,280,193

INDUSTRY BURDEN HOURS
DEVELOPMENT
Facility Plans
Annual Review
Annual Recordkeeping
Submittals

YEAR
FREQUENCY
1
(x 1)
2 thru 5
(x 1)
1 thru 5
(x 1)
5
(x 1/5)
Total Annual Burden Hours on Industry (1-5)

Note:
$35 represents the average hourly wage of facility personnel
1
Total reflects the weighted average burden for all model facilities,
rounded to two significant digits after the decimal point.

HOURS
REQUIRED
32,400
38,810
19,405
3,105
93,720

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Table VRP
INDUSTRY REPORTING BURDEN/COSTS
INITIAL PLAN DEVELOPMENT
Number of Plans

Burden Hours

Total Burden
Hours

Per Plan
111 VR Plans

40

4,440 x$100/hr=

Cost

$444,000

PLAN MAINTENANCE AND REVISION
Number of Revisions

Hours

6,840 Revisions (Correspondence)

3

Total Burden
Hours
20,520 x $100/hr=

Cost

$2,052,000

ANNUAL RECORDKEEPING BURDEN
Industry

Hours

798 VR Plans

5

Total Burden
Hours
3,990 x $40/hr=

Cost

$159,600

FIFTH YEAR SUBMITTAL BURDEN
Number of Plans
798 VR Plans

Hours
4

Total Burden
Hours
3,192 x 0.2
638.4 x $100/hr=
Total Annual Cost

Cost

$63,840
$2,719,440

INDUSTRY BURDEN HOURS
DEVELOPMENT
Vessel Plans
Review/Revisions
Recordkeeping
Submittals

YEAR
FREQUENCY
1
(x 1)
2 thru 5
(x 1)
1 thru 5
(x 1)
5
(x 1/5)
Total Annual Burden Hours on Industry (1-5)

HOURS
REQUIRED
4,440
20,520
3,990
638
29,588

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Table NTVRP
INDUSTRY REPORTING BURDEN/COSTS
INITIAL PLAN DEVELOPMENT
Number of Plans

Burden Hours

Total Burden
Hours

Per Plan
280 NTVR Plans

40

11,200 x$100/hr=

Cost

$1,120,000

PLAN MAINTENANCE AND REVISION
Number of Revisions

Hours

4,156 Revisions (Correspondence)

3

Total Burden
Hours
12,468 x $100/hr=

Cost

$1,246,800

ANNUAL RECORDKEEPING BURDEN
Industry

Hours

2,000 NTVR Plans

5

Total Burden
Hours
10,000 x $40/hr=

Cost

$400,000

FIFTH YEAR SUBMITTAL BURDEN
Number of Plans

Hours

2,000 NTVR Plans

4

Total Burden
Hours
8,000 x 0.2
1600 x $100/hr=
Total Annual Cost

Cost

$160,000
$2,926,800

INDUSTRY BURDEN HOURS
DEVELOPMENT
Vessel Plans
Review/Revisions
Recordkeeping
Submittals

YEAR
FREQUENCY
1
(x 1)
2 thru 5
(x 1)
1 thru 5
(x 1)
5
(x 1/5)
Total Annual Burden Hours on Industry (1-5)

HOURS
REQUIRED
11,200
12,468
10,000
1,600
35,268

1625-0066 (formerly 2115-0595)

Table PWS
Industry Reporting Burden

Requirements

Hours

Costs

Operational Readiness:
Technical ($50/hour)
Clerical ($20/hour)
Total

200
80
280

$ 10,000
$
1,600
$ 11,600

480
120
600

$ 24,000
$
2,400
$ 26,400

Drills:
Technical ($50/hour)
Clerical ($20/hour)
Total

Industry Recordkeeping Burden
Training:
Clerical
Total

($20/hour)

400
400
Total Hours

$
$

8,000
8,000

1,280

Total Costs

$ 46,000