Burden Calculation Tables

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Overview

Table 1
Table 2

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Sheet 1: Table 1

Table 1: Annual Respondent Burden and Cost – NSPS for Storage Vessels for Petroleum Liquids for Which Construction, Reconstruction or Modification Commenced After June 11, 1973 and Prior to May 19, 1978 (40 CFR Part 60, Subpart K) (Renewal)
					122.2	153.55	61.51
Burden Item	(A) Technical person-hours per occurrence	(B) No. of occurrences per respondent per year	(C) Technical person-hours per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical person hours per year (E=CxD)	(F) Management hours per year (F=Ex0.05)	(G) Clerical hours per year (G=Ex0.1)	(H) Total Cost per year ($) b
1. Applications	N/A
2. Surveys and studies	N/A
3. Reporting requirements
A. Familiarize with regulatory requirements c	1	1	1	281	281	14.05	28.1	$38,224.01
B. Required activities:	See 3D
i. Monitoring of operations and emissions d	See 3D
C. Gather existing information	See 3D and 4E
D. Write notification
i. Notification of reconstruction/modification	N/A
ii. Notification of physical or operational change e	4	1	4	2.81	11.24	0.562	1.124	$1,528.96
Subtotal for Reporting Requirements					336			$39,753
4. Recordkeeping requirements
A. Familiarize with regulatory requirements c	See 3A
B. Plan activities	See 3E
C. Implement activities	See 3E
D. Develop record system	N/A
E. Time to enter and transmit information:
i. Records of startup, shutdown, or malfunction	1	1	1	281	281	14.05	28.1	$38,224.01
ii. Record petroleum liquid stored	0.5	1	0.5	281	140.5	7.025	14.05	$19,112.00
iii. Record of storage performance tests	0.5	1	0.5	281	140.5	7.025	14.05	$19,112.00
iv. Record true vapor pressure of liquid stored	1	1	1	281	281	14.05	28.1	$38,224.01
F. Time to train personnel	N/A
G. Time for audits	N/A
Subtotal for Recordkeeping Requirements					969			$114,672
TOTAL ANNUAL BURDEN AND COST (rounded) f					1,310			$154,000
TOTAL CAPITAL AND O&M COST (rounded) f								$0
GRAND TOTAL (rounded) f								$154,000
Assumptions:
a We assume there are approximately 281 sources currently subject to the standard, and that there will be no new sources over the three-year period of this ICR.
b This ICR uses the following labor rates: $122.20 for technical, $153.55 for managerial, and $61.51 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2021, “Table 2. Civilian Workers, by occupational and industry group.” The rates are from column 1, “Total compensation.” The rates have been increased by 110 percent to account for varying industry wage rates and the additional overhead business costs of employing workers beyond their wages and benefits, including business expenses associated with hiring, training, and equipping their employees.
c This ICR assumes all respondents will take 1 hour to familiarize with regulatory requirements.
d Monitoring and recordkeeping operations include maintaining records of the petroleum liquid stored, the period of storage, and the maximum true vapor pressure of that liquid during the respective storage period, unless the affected facility is equipped with a vapor recovery and return or disposal system in accordance with the requirements in 40 CFR 60.112, or stores liquid with a Reid vapor pressure of less than 6.9 kPa (1.0 psia), provided the true vapor pressure does not exceed that value.
e We assume only one percent of respondents (i.e., 0.01 of 281, or 2.81 respondents) will make physical or operational changes to their tanks in such way that will trigger reporting requirements under the standard.
f Figures have been rounded 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 2: Table 2

Table 2: Average Annual EPA Burden and Cost – NSPS for Storage Vessels for Petroleum Liquids for Which Construction, Reconstruction or Modification Commenced After June 11, 1973 and Prior to May 19, 1978 (40 CFR Part 60, Subpart K) (Renewal)
					51.23	69.04	27.73
Burden Item	(A) Technical person-hours per occurrence	(B) No. of occurrences per respondent per year	(C) Technical person-hours per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical person hours per year (E=CxD)	(F) Management hours per year (F=Ex0.05)	(G) Clerical hours per year (G=Ex0.1)	(H) Total Cost per year ($) b
Notification of reconstruction/modification	N/A
Notification of physical or operational change c	2	1	2	2.81	5.62	0.281	0.562	$322.90
TOTAL ANNUAL BURDEN AND COST (rounded) d					6			$323
Assumptions:
a We assume there are approximately 281 sources currently subject to the standard, and that there will be no new sources over the three-year period of this ICR.
b This ICR uses the following labor rates: $51.23 for technical, $69.04 for managerial, and $27.73 for clerical labor. These rates are from the Office of Personnel Management (OPM), 2021 General Schedule, which excludes locality rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees.
c We assume only one percent of respondents (i.e., 0.01 of 281, or 2.81 respondents) will make physical or operational changes to their tanks in such way that will trigger reporting requirements under the standard.
d Figures have been rounded 3 significant figures. Figures may not add exactly due to rounding.