The information in state databases was matched with the Dun & Bradstreet (D&B) Market Spectrum database to assign industry sectors. To extrapolate the estimates to the entire country, these values were multiplied by a facility ratio. The facility ratio was estimated as the number of SPCC-regulated facilities in the eight states for an industry sector divided by the total number of facilities reported for that industry sector in those states.

 	Estimates based on national-level data

      Because of the availability of federal and proprietary data, EPA used a different estimation approach for the following industry sectors: petroleum bulk stations and terminals; fuel oil dealers; pipelines; petroleum refinery and related industries; oil and gas production; farms; electric utilities; and manufacturing facilities handling or storing animal fats and vegetable oils. These sectors represent 70 percent of the facilities affected by the SPCC rule.

      The 2002 Economic Census was used to estimate the number of regulated facilities for the petroleum bulk stations and terminals, fuel oil dealers, pipelines, and petroleum refinery and related industries. As in previous analyses, all facilities in these industries were assumed to be regulated under the SPCC rule.

      EPA assumed all oil production facilities are regulated under the SPCC rule. Certain gas production facilities may also be regulated, given that some gas wells have tanks for storing condensate oil generated during the gas-production process. EPA used Energy Information Administration (EIA) data to estimate the total number of oil-production wells as well as gas wells that produce condensate oil. All active wells that were producing in 2004 are considered in the analysis. The EIA database contains historical data on oil and gas wells, including marginal wells, compiled from government and commercial sources.  EIA provides data on oil and oil-condensate produced at oil and gas production wells according to various production-rate classes. Gas wells that do not produce oil condensate are not included. To convert the number of wells that produce oil and oil condensate to the total number of SPCC-regulated production facilities, EPA assumed four wells per facility based on personal communication with industry experts.  Under this assumption, EPA estimated that approximately 166,000 oil production facilities are SPCC-regulated.

      The number of farms was calculated based on Census of Agriculture data on production expenses related to petroleum-related purchases from 2002 and 1997 and on diesel storage data from 1982.  In the 2002 Census of Agriculture, expenditure data are available only in aggregate for all fuels. To arrive at the expenditure on diesel (gasoline) in 2002, EPA multiplied the total expenditure on fuels in 2002 by the ratio of diesel (gasoline) expenditure to total expenditure from the 1997 data. The Agency assumed that the percentage of diesel (gasoline) expenditure remained the same from 1997 through 2002.  Finally, the total quantity of diesel (gasoline) purchased in 2002 was calculated by dividing the expenditure on diesel (gasoline) by diesel (gasoline) prices. Using 1982 data on fuel storage and expenditures on farms, the ratio of diesel (gasoline) storage with respect to the annual quantity of diesel (gasoline) purchased was calculated.  On average approximately one-fifth of the annual quantity of diesel purchased and about one fourth of the annual quantity of gasoline purchased is stored on farms.  Since no data were available on the type of storage (i.e., aboveground or underground) EPA assumed that the entire storage is aboveground. The expenditure ranges were converted to capacity ranges and assigned to a percentage of farms that are regulated within the capacity ranges.

      EPA calculated the number of SPCC-regulated electric utility plants as a combination of the number of substations and the number of power plants in the United States. All electricity generation facilities and substations are assumed to contain enough oil to be subject to SPCC requirements. The number of electric utility plants was estimated based on data reported by the Energy Information Administration (EIA). The number of substations was estimated based on the number of substations listed by each major utility reporting to the Federal Energy Regulatory Commission (FERC).  A national estimate was extrapolated from these data using the ratio of the megawatt hours sold by utilities to the estimated total retail megawatt hours of electricity sold nationwide according to the EIA.

      Facilities handling or storing non-petroleum oil are also subject to SPCC regulations.  Non-petroleum oils include, but are not limited to, animal fats and oils and greases, or fish and marine mammal oils; and, oils of vegetable origin, including oils from seeds, nuts, fruits, and kernels. To estimate the number of facilities that could produce or store animal fat or vegetable oil, EPA used data on the number of manufacturing establishments from the 2005 U.S. Census of Manufacturing.  Four possible types of AFVO facilities were considered:  (1) industries that produce AFVO; (2) industries that use AFVO as a primary input; (3) industries that use AFVO in moderate amounts; and (4) industries that use AFVO as a minor component of their input. EPA assumed that all facilities that produce AFVO (group 1) are SPCC-regulated. Then, low, medium, and high estimates were developed using professional judgment for industries in the remaining three groups regarding the percentage of each industry group assumed to be regulated by the SPCC rule. EPA also identified a category of "other" facility types that may produce or use AFVO.  For these facilities, specific information on the number of regulated facilities was available and was used instead of the assumed percentages. This methodology yielded estimates of the number of facilities that may be regulated based only on their storage of AFVO. Some of these facilities are probably regulated because they also store petroleum oils.

      On April 18, 2011, EPA published a final rule that exempted milk and milk product containers and appurtenances from the SPCC regulations. As a result, a portion of the universe of dairy farms and milk manufacturing facilities became exempt from the SPCC regulations or shifted to a lower category.  For example, a Category I facility that could self certify their SPCC plan may be eligible to use a Tier I qualified facility template plan. This change in the SPCC facility regulatory requirements is reflected in the adjustment to the farm universe in this ICR, that led to a lower number of farms for 2014.

  	Industry Growth Rates

       To project the number of existing and new facilities regulated under the SPCC rule over the 2014 through 2016 ICR period, EPA used industry-specific growth rates for new and existing facilities.  EPA's previous approach was to apply a uniform one-percent growth rate across all sectors, which did not account for significant variations (including negative growth rates) among the sectors.

       To estimate industry-specific growth rates for existing facilities of all SPCC-related industry categories except farms and oil production, EPA used 1992, 1997, and 2002 U.S. Economic Census data on the number of establishments in each industry. The use of an extended time period to estimate industry-specific growth rates attempted to account for diverse economic conditions under which SPCC-regulated industries operate. To estimate annual growth rates for agricultural establishments, EPA used data reported by the USDA National Agricultural Statistics Service on the number of farms in the United States over the past 10 years (1996 through 2005). The data for the past 10 years were expected to be more representative of the latest developments in the agricultural business than data for years prior to 1996.

       EPA estimated the growth rates for new facilities only using commercially available data obtained on the number of businesses (by NAICS code) in 2005 from the D&B Market Spectrum database. These data allowed for an estimation of the fraction of businesses that became operational in 2005 relative to the total number of businesses in that year. This analysis assumed that industry growth rates would be constant over the 10-year analytical period for all industries except oil production, which may or may not adequately represent the trends for individual sectors.

       Because oil production facilities account for the largest fraction of SPCC-regulated facilities across all industry categories and represent a dynamic industry, an alternative approach was used for estimating future oil production industry growth rates.  EPA relied on industry-specific forecasting information, which was expected to reflect growth rates better than an approach based on historical trends.  EPA estimated annual growth rates for the oil production facilities relying on historical and forecasted U.S. oil production data and historical number of oil wells.  The approach used to estimate the growth rates for oil production facilities is described in the regulatory impact analysis for the 2008 SPCC final rule.

 	In total, EPA estimated that 640,000 facilities would be regulated by the SPCC rule in 2010.  Oil production facilities (34 percent), farms (23 percent), and electric utilities (10 percent) account for the majority of SPCC-regulated facilities.

 	Exhibit 10 and Exhibit 11 present the estimated number of existing and new SPCC-regulated facilities that are expected to incur paperwork-related burden associated with the final amendments to the SPCC rule. Exhibit 10 presents the number of facilities by facility type - storage and production facilities - for the first year of the ICR, 2014. Exhibit 11 presents the number of facilities for the entire analysis period, 2014 - 2016.
Exhibit 10
                     Number of Existing and New Facilities
                           (First Year of ICR: 2014)
                                 Facility Type
                       Category I (1,320-10,000 gallons)
                      Category II (10,001-42,000 gallons)
                  Category III (42,001 to 1 million gallons)
                      Category IV (>1 million gallons)
                                     Total

Storage
                                                                        288,000
                                                                         80,800
                                                                         35,700
                                                                          2,980
                                                                        408,000
Existing
Production
                                                                         29,000
                                                                        157,000
                                                                         41,300
                                                                            405
                                                                        228,000

Total
                                                                        317,000
                                                                        238,000
                                                                         77,000
                                                                          3,380
                                                                        636,000

Storage
                                                                          5,750
                                                                          2,400
                                                                          1,070
                                                                             80
                                                                          9,300
New
Production
                                                                          1,540
                                                                          8,270
                                                                          2,170
                                                                             21
                                                                         12,000

Total
                                                                          7,290
                                                                         10,670
                                                                          3,240
                                                                            101
                                                                         21,300
Total
                                                                        324,000
                                                                        249,000
                                                                         80,200
                                                                          3,480
                                                                        657,000
 Note: values may not total due to rounding.
Exhibit 11
                     Number of Existing and New Facilities
                           (ICR Period: 2014 - 2016)

                              Facility Type/ Year
                       Category I (1,320-10,000 gallons)
                      Category II (10,001-42,000 gallons)
                  Category III (42,001 to 1 million gallons)
                      Category IV (>1 million gallons)
                                     Total
Existing
Year 1 - 2014
                                                                       318,000
                                                                        238,000
                                                                         77,000
                                                                         3,380
                                                                       636,000

Year 2 - 2015
                                                                       321,000
                                                                        243,000
                                                                         78,400
                                                                         3,410
                                                                       645,000

Year 3 - 2016
                                                                       324,000
                                                                        246,000
                                                                        79,400
                                                                         3,430
                                                                       653,000
New
Year 1 - 2014
                                                                         7,280
                                                                        10,700
                                                                         3,240
                                                                           102
                                                                        21,300

Year 2 - 2015
                                                                         7,840
                                                                        12,800
                                                                         3,830
                                                                           110
                                                                        24,600

Year 3 - 2016
                                                                         8,680
                                                                        16,400
                                                                         4,790
                                                                           123
                                                                        30,000
Total
Year 1 - 2014
                                                                       325,000
                                                                       249,000
                                                                        80,200
                                                                         3,490
                                                                       657,000

Year 2 - 2015
                                                                       329,000
                                                                       256,000
                                                                        82,000
                                                                         3,520
                                                                       670,000

Year 3 - 2016
                                                                       333,000
                                                                       262,000
                                                                        84,000
                                                                         3,550
                                                                       683,000
 Note: values may not total due to rounding.

 	6(e)	Estimated Total Annual Burden for All Respondents

      The total hour burden is estimated as the average per-facility burden multiplied by the number of affected facilities. Similarly, the total cost burden for all respondents is estimated by multiplying the number of facilities in each size category by the unit costs for each compliance activity. The total annual burden and costs for all respondents in each category are presented in Exhibit 13 through Exhibit 17 for each facility size. The annual average total burden is estimated at 8.8 million hours; the annual average total cost is estimated at $987 million.

	Alternative Estimates

      EPA also calculated alternative cost estimates based on higher overhead rates for labor costs, which are presented in Exhibit 12. The primary estimates are based on a 17 percent overhead rate and the alternatives are calculated assuming a 50 percent overhead rate and a 100 percent overhead rate.  The discussion of facility labor costs in section 6(a) describes how the overhead rates affect wage rates.  Under the primary assumption, the estimated total annualized burden of the information collection is $987 million. Under the alternative assumptions, the estimated total burden ranges from $1,211 to $1,556 million.

Exhibit 12
                     Sensitivity Analysis for Total Cost
                            Varying Overhead Rates
                               (2012$, Millions)
                                  Assumption
                                     Labor
                                    Capital
                                    O&M
                                     Total

                                Baseline Burden
17% Overhead
                                                                          $801
                                                                          $3.0
                                                                          $184
                                                                          $987
50% Overhead
                                                                        $1,025
                                                                          $3.0
                                                                           $184
                                                                        $1,211
100% Overhead
                                                                         $1,369
                                                                          $3.0
                                                                           $184
                                                                        $1,556

Exhibit 13
               Total Annual Burden and Costs for All Facilities
                    Average Category I Facilities (Tier I)
 Activity
                            Annual Burden Hours[1]
                              Total Burden Hours
                             Capital/Startup Costs
                                   PE Costs
                            Annual Cost (2012$)[2]

                                  Management
                                   Technical
                                    Drafter
                                   Clerical

Existing Facilities
Review the SPCC Plan
                                                                         92,000
                                                                        707,000
                                                                              0
                                                                          92,00
                                                                        861,000
                                                                             $0
                                                                             $0
                                                                    $80,100,000
Submit Information in the Event of Certain Discharges of Oil
                                                                            370
                                                                            370
                                                                              0
                                                                              0
                                                                            741
                                                                         $7,434
                                                                             $0
                                                                        $55,000
Revise the SPCC Plan
                                                                         76,600
                                                                        460,000
                                                                              0
                                                                         61,300
                                                                        598,000
                                                                             $0
                                                                             $0
                                                                   $121,515,000
Maintain the SPCC Plan and Keep Records
                                                                              0
                                                                        652,000
                                                                              0
                                                                              0
                                                                        652,000
                                                                             $0
                                                                             $0
                                                                    $38,066,000
TOTAL
                                                                        169,000
                                                                      1,819,000
                                                                              0
                                                                        153,000
                                                                      2,141,000
                                                                         $7,434
                                                                             $0
                                                                   $239,736,000
New Facilities
Prepare an SPCC Plan
                                                                              0
                                                                         18,300
                                                                              0
                                                                              0
                                                                         18,300
                                                                             $0
                                                                             $0
                                                                       $971,000
Prepare a Contingency Plan
                                                                          3,980
                                                                         21,100
                                                                              0
                                                                          5,850
                                                                         31,000
                                                                             $0
                                                                             $0
                                                                     $1,383,000
Submit Information in the Event of Certain Discharges of Oil
                                                                              9
                                                                              9
                                                                              0
                                                                              0
                                                                             18
                                                                           $184
                                                                             $0
                                                                         $1,250
Revise the SPCC Plan
                                                                             22
                                                                            131
                                                                              0
                                                                             17
                                                                            170
                                                                             $0
                                                                             $0
                                                                        $34,600
Maintain the SPCC Plan and Keep Records
                                                                              0
                                                                         23,200
                                                                              0
                                                                              0
                                                                         23,200
                                                                       $698,000
                                                                             $0
                                                                     $3,203,000
TOTAL
                                                                          4,020
                                                                         62,800
                                                                              0
                                                                          5,870
                                                                         72,700
                                                                       $698,000
                                                                             $0
                                                                     $5,593,000
[1] Unit burden estimates are estimated totals, rounded to the nearest three significant figures of an hour, based on the distribution of storage and production facilities and the number of facilities estimated to perform each activity during the one-year period.  The numbers in this exhibit may not add precisely due to rounding.

[2] Annual costs are rounded to the three significant figures.

Exhibit 14
            Total Annual Burden and Costs for All Other Facilities
                         Average Category I Facilities
 Activity
                            Annual Burden Hours[1]
                              Total Burden Hours
                             Capital/Startup Costs
                                   PE Costs
                            Annual Cost (2012$)[2]

                                  Management
                                   Technical
                                    Drafter
                                   Clerical

Existing Facilities
Review the SPCC Plan
                                                                         27,500
                                                                        211,000
                                                                              0
                                                                         27,500
                                                                        266,000
                                                                             $0
                                                                             $0
                                                                    $23,900,000
Submit Information in the Event of Certain Discharges of Oil
                                                                            111
                                                                            111
                                                                              0
                                                                              0
                                                                            221
                                                                         $2,220
                                                                             $0
                                                                        $16,300
Revise the SPCC Plan
                                                                         22,900
                                                                        137,000
                                                                              0
                                                                         18,300
                                                                        178,000
                                                                             $0
                                                                             $0
                                                                    $36,300,000
Maintain the SPCC Plan and Keep Records
                                                                              0
                                                                        195,000
                                                                              0
                                                                              0
                                                                        195,000
                                                                             $0
                                                                             $0
                                                                    $11,400,000
TOTAL
                                                                         50,500
                                                                        543,000
                                                                              0
                                                                         45,800
                                                                        639,000
                                                                         $2,220
                                                                             $0
                                                                    $71,616,000
New Facilities
Prepare an SPCC Plan
                                                                          3,360
                                                                         50,000
                                                                         18,500
                                                                          6,750
                                                                         78,500
                                                                             $0
                                                                             $0
                                                                     $6,420,000
Prepare a Contingency Plan
                                                                          1,190
                                                                          6,320
                                                                              0
                                                                          1,750
                                                                          9,250
                                                                             $0
                                                                             $0
                                                                       $413,000
Submit Information in the Event of Certain Discharges of Oil
                                                                              3
                                                                              3
                                                                              0
                                                                              0
                                                                              5
                                                                            $55
                                                                             $0
                                                                           $372
Revise the SPCC Plan
                                                                              7
                                                                             39
                                                                              0
                                                                              5
                                                                             51
                                                                             $0
                                                                             $0
                                                                        $10,300
Maintain the SPCC Plan and Keep Records
                                                                              0
                                                                          6,930
                                                                              0
                                                                              0
                                                                          6,930
                                                                       $209,000
                                                                             $0
                                                                       $957,000
TOTAL
                                                                          4,560
                                                                         63,000
                                                                         18,500
                                                                          8,500
                                                                         94,800
                                                                       $209,000
                                                                             $0
                                                                     $7,800,000
[1] Unit burden estimates are estimated totals, rounded to the nearest three significant figures of an hour, based on the distribution of storage and production facilities and the number of facilities estimated to perform each activity during the one-year period.  The numbers in this exhibit may not add precisely due to rounding.

[2] Annual costs are rounded to the three significant figures.
Exhibit 15
               Total Annual Burden and Costs for All Facilities
                        Average Category II Facilities
 Activity
                            Annual Burden Hours[1]
                              Total Burden Hours
                             Capital/Startup Costs
                                   PE Costs
                            Annual Cost (2012$)[2]

                                  Management
                                   Technical
                                    Drafter
                                   Clerical

Existing Facilities
Review the SPCC Plan
                                                                         64,900
                                                                        973,000
                                                                              0
                                                                         65,000
                                                                      1,103,000
                                                                             $0
                                                                             $0
                                                                   $100,500,000
Submit Information in the Event of Certain Discharges of Oil
                                                                            363
                                                                            363
                                                                              0
                                                                              0
                                                                            726
                                                                         $7,288
                                                                             $0
                                                                        $53,700
Revise the SPCC Plan
                                                                        105,000
                                                                        633,000
                                                                              0
                                                                         84,400
                                                                        823,000
                                                                             $0
                                                                    $87,029,000
                                                                   $161,400,000
Maintain the SPCC Plan and Keep Records
                                                                              0
                                                                        887,000
                                                                              0
                                                                              0
                                                                        887,000
                                                                             $0
                                                                             $0
                                                                    $52,000,000
TOTAL
                                                                        170,000
                                                                      2,493,000
                                                                              0
                                                                        149,000
                                                                      2,813,000
                                                                         $7,288
                                                                    $87,029,000
                                                                   $314,000,000
New Facilities
Prepare an SPCC Plan
                                                                         37,700
                                                                        517,000
                                                                        201,000
                                                                         67,800
                                                                        823,000
                                                                             $0
                                                                    $26,100,000
                                                                    $93,600,000
Prepare a Contingency Plan
                                                                          8,670
                                                                         46,000
                                                                              0
                                                                         12,700
                                                                         67,400
                                                                             $0
                                                                             $0
                                                                     $3,000,000
Submit Information in the Event of Certain Discharges of Oil
                                                                             20
                                                                             20
                                                                              0
                                                                              0
                                                                             40
                                                                           $440
                                                                             $0
                                                                         $2,940
Revise the SPCC Plan
                                                                             61
                                                                            366
                                                                              0
                                                                             49
                                                                            476
                                                                             $0
                                                                        $50,000
                                                                        $93,000
Maintain the SPCC Plan and Keep Records
                                                                              0
                                                                         18,600
                                                                              0
                                                                              0
                                                                         18,600
                                                                     $1.519,000
                                                                             $0
                                                                     $5,187,000
TOTAL
                                                                         46,500
                                                                        582,000
                                                                        201,000
                                                                         80,500
                                                                        910,000
                                                                     $1,519,000
                                                                    $26,100,000
                                                                   $102,000,000
[1] Unit burden estimates are estimated totals, rounded to the nearest three significant figures of an hour, based on the distribution of storage and production facilities and the number of facilities estimated to perform each activity during the one-year period.  The numbers in this exhibit may not add precisely due to rounding.

[2] Annual costs are rounded to the three significant figures.
Exhibit 16
               Total Annual Burden and Costs for All Facilities
                        Average Category III Facilities
 Activity
                            Annual Burden Hours[1]
                              Total Burden Hours
                             Capital/Startup Costs
                                   PE Costs
                            Annual Cost (2012$)[2]

                                  Management
                                   Technical
                                    Drafter
                                   Clerical

Existing Facilities
Review the SPCC Plan
                                                                         38,600
                                                                        578,000
                                                                              0
                                                                         38,600
                                                                        655,000
                                                                             $0
                                                                             $0
                                                                    $59,700,000
Submit Information in the Event of Certain Discharges of Oil
                                                                            117
                                                                            117
                                                                              0
                                                                              0
                                                                            235
                                                                         $2,354
                                                                             $0
                                                                        $17,300
Revise the SPCC Plan
                                                                         62,600
                                                                        376,000
                                                                              0
                                                                         50,100
                                                                        489,000
                                                                             $0
                                                                    $51,372,000
                                                                    $95,500,000
Maintain the SPCC Plan and Keep Records
                                                                              0
                                                                        349,000
                                                                              0
                                                                              0
                                                                        349,000
                                                                             $0
                                                                             $0
                                                                    $20,400,000
TOTAL
                                                                        101,300
                                                                      1,303,000
                                                                              0
                                                                         88,700
                                                                      1,493,000
                                                                         $2,354
                                                                    $51,372,000
                                                                   $176,000,000
New Facilities
Prepare an SPCC Plan
                                                                         22,400
                                                                        287,000
                                                                        119,000
                                                                         23.700
                                                                        452,000
                                                                             $0
                                                                    $14,430,000
                                                                    $51,500,000
Prepare a Contingency Plan
                                                                          2,579
                                                                         13,700
                                                                              0
                                                                          3,786
                                                                         20,100
                                                                             $0
                                                                             $0
                                                                       $895,000
Submit Information in the Event of Certain Discharges of Oil
                                                                              6
                                                                              6
                                                                              0
                                                                              0
                                                                             12
                                                                           $119
                                                                             $0
                                                                           $875
Revise the SPCC Plan
                                                                             35
                                                                            207
                                                                              0
                                                                             28
                                                                            269
                                                                             $0
                                                                             $0
                                                                             $0
Maintain the SPCC Plan and Keep Records
                                                                              0
                                                                          7,510
                                                                              0
                                                                              0
                                                                          7,510
                                                                       $570,000
                                                                             $0
                                                                     $1,990,000
TOTAL
                                                                         25,000
                                                                        309,000
                                                                        119,000
                                                                         27,500
                                                                        480,000
                                                                       $570,000
                                                                    $14,430,000
                                                                    $54,400,000
[1] Unit burden estimates are estimated totals, rounded to the nearest three significant figures of an hour, based on the distribution of storage and production facilities and the number of facilities estimated to perform each activity during the one-year period.  The numbers in this exhibit may not add precisely due to rounding.

[2] Annual costs are rounded to the three significant figures.

Exhibit 17
               Total Annual Burden and Costs for All Facilities
                        Average Category IV Facilities
 Activity
                            Annual Burden Hours[1]
                              Total Burden Hours
                             Capital/Startup Costs
                                   PE Costs
                            Annual Cost (2012$)[2]

                                  Management
                                   Technical
                                    Drafter
                                   Clerical

Existing Facilities
Review the SPCC Plan
                                                                          2,940
                                                                         44,400
                                                                              0
                                                                          2,940
                                                                         50,300
                                                                             $0
                                                                             $0
                                                                     $4,600,000
Submit Information in the Event of Certain Discharges of Oil
                                                                              5
                                                                              5
                                                                              0
                                                                              0
                                                                             10
                                                                           $102
                                                                             $0
                                                                           $754
Revise the SPCC Plan
                                                                          4,880
                                                                         28,700
                                                                              0
                                                                          3,830
                                                                         37,400
                                                                             $0
                                                                     $3,960,000
                                                                     $7,340,000
Maintain the SPCC Plan and Keep Records
                                                                          1,220
                                                                         40,200
                                                                              0
                                                                          2,450
                                                                         43,800
                                                                             $0
                                                                             $0
                                                                     $2,400,000
TOTAL
                                                                          9,050
                                                                        113,300
                                                                              0
                                                                          9,220
                                                                        131,600
                                                                           $102
                                                                     $3,960,000
                                                                    $14,000,000
New Facilities
Prepare an SPCC Plan
                                                                          1,216
                                                                         14,100
                                                                          4,580
                                                                          1,520
                                                                         21,400
                                                                             $0
                                                                       $727,000
                                                                     $2,490,000
Prepare a Contingency Plan
                                                                             73
                                                                            386
                                                                              0
                                                                            107
                                                                            566
                                                                             $0
                                                                             $0
                                                                        $25,300
Submit Information in the Event of Certain Discharges of Oil
                                                                              0
                                                                              0
                                                                              0
                                                                              0
                                                                              0
                                                                             $3
                                                                             $0
                                                                            $25
Revise the SPCC Plan
                                                                              2
                                                                             10
                                                                              0
                                                                              1
                                                                             14
                                                                             $0
                                                                         $1,450
                                                                         $2,680
Maintain the SPCC Plan and Keep Records
                                                                              0
                                                                            792
                                                                              0
                                                                              0
                                                                            792
                                                                        $19,800
                                                                             $0
                                                                        $98,300
TOTAL
                                                                          1,290
                                                                         15,300
                                                                          4,580
                                                                          1,630
                                                                         22,700
                                                                        $19,800
                                                                       $728,000
                                                                     $2,610,000
[1] Unit burden estimates are estimated totals, rounded to the nearest three significant figures of an hour, based on the distribution of storage and production facilities and the number of facilities estimated to perform each activity during the one-year period.  The numbers in this exhibit may not add precisely due to rounding.

[2] Annual costs are rounded to the three significant figures.

 6(f)	Bottom Line Burden and Cost Tables

 	The total estimated burden hours and costs incurred by all new and existing facilities are summarized in Exhibit 18. The exhibit shows the burden and cost components for each year of this ICR, along with total and annualized costs.

Exhibit 18
                Estimated Total Burden and Costs for Facilities
                                     Year
                         Total Burden (million hours)
                         Total Cost (2012$, millions)

                                     Labor
                                    Capital
                                    O&M
                                     Total
First
                                                                            8.4
                                                                          $768
                                                                          $2.2
                                                                          $173
                                                                          $944
Second
                                                                            8.8
                                                                          $797
                                                                          $2.6
                                                                           $183
                                                                          $982
Third
                                                                            9.2
                                                                          $836
                                                                          $3.1
                                                                          $195
                                                                        $1,034
TOTAL
                                                                           26.4
                                                                        $2,402
                                                                          $8.0
                                                                          $551
                                                                        $2,961
ANNUALIZED
                                                                            8.8
                                                                          $801
                                                                          $3.0
                                                                          $184
                                                                          $987

 6(g) 	Reasons for the Change in Burden

	Differences in burden and costs from the previous ICR are attributed to adjustments for wage rates and the projected universe of facilities over the covered period 2014 through 2016. Adjustments capture updates to the number of affected facilities and wages. The only program change that affected the ICR was the final rule to exempt milk and milk product containers and associated piping and appurtenances published in April 2011. As a result, EPA estimated that approximately 66,000 farms and milk product manufacturing facilities were affected by this amendment and this is reflected in the projections for farms over the 2014  -  2016 ICR period. EPA estimates that there will be a reduction of approximately 100,000 annual burden hours and savings of $4 million in costs as a result of this program change. These savings are accounted for in the March 24, 2011 RIA for the final milk and milk product container exemption rule.

	Exhibit 19 presents the annual burden hours and costs. In total, the burden hours presented in this ICR have increased relative to the current OMB inventory. The new burden estimate shows a net annual increase of approximately 760,000 hours. The Agency estimates that capital and O&M costs would increase by approximately $26 million due to a change in the universe of regulated facilities. This is partially offset by $4 million in savings from the milk and milk product container exemption, leaving a net increase of $22 million in capital and O&M. The increase in hours and capital and O&M is attributable to a small increase in wage rates and the population of facilities in the universe estimated over the 2014 through 2016 covered period.

Exhibit 19
      Total Estimated Annual Burden Hours and Annualized Costs Comparison

                              Annual Burden Hours
                     Annualized Capital and O&M Costs
Previous ICR 0328.15 Burden
                                                                      8,041,358
                                                                   $161,008,709
Change in Burden

                                                                       +757,570
                                                                   +$25,666,105
ICR 0328.16 Burden
                                                                      8,798,928
                                                                   $186,674,814

 	The exhibits below present the change in burden (hours and costs) as compared to the burden estimates currently approved by OMB. The exhibits show change in burden separately for Private facilities (Exhibit 21) and State and Local Government facilities (Exhibit 22).
Exhibit 21
Total Estimated Annual Burden and Costs Comparison: Private

Total Requested
Change from previous ICR
Currently Approved
Annual Responses
669,445
+18,002
651,443
Annual Hour Burden
8,791,010
+757,125
8,033,885
Annual Cost Burden (Capital/StartUp and O&M costs)
$186,506,819
+$25,647,748
$160,859,071

                                  Exhibit 22
Total Estimated Annual Burden and Costs Comparison: State and Local Government Facilities

                                Total Requested
                            Change for previous ICR
                              Currently Approved
Annual Responses
                                                                            603
                                                                             -3
                                                                            606
Annual Hour Burden
                                                                          7,918
                                                                           +445
                                                                          7,473
Annual Cost Burden (Capital/StartUp and O&M costs)

                                                                       $167,995

                                                                        +18,357

                                                                       $149,638

 6(h) 	Burden Statement

      The annual public reporting and recordkeeping burden for this collection of information is estimated to average 13 hours per response.
      The annual public reporting and recordkeeping burden for this collection of information for newly regulated facilities is estimated to range from 11.9 to 203.9 hours per facility, with an average burden of approximately 58 hours per response. The net annual public reporting and recordkeeping burden for facilities already regulated by the rule is estimated to range from 8.7 to 38.4 hours, with an average burden of approximately 11 hours.

	Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with any previously applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information.  An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number. The OMB control numbers for EPA's regulations are listed in 40 CFR part 9 and chapter 15 of 48 CFR.

	To comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this ICR under Docket ID Number [EPA-HQ-OPA-2007-0584], which is available for online viewing at www.regulations.gov, or in person viewing at the Superfund Docket in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Avenue, NW, Washington, D.C.  The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number for the Reading Room is<PHONE_NUMBER>, and the telephone number for the Superfund Docket is<PHONE_NUMBER>. An electronic version of the public docket is available at www.regulations.gov. This site can be used to submit or view public comments, access the index listing of the contents of the public docket, and to access those documents in the public docket that are available electronically.  When in the system, select "search," then key in the Docket ID Number identified above.  Also, comments can be sent to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, D.C. 20503, Attention: Desk Officer for EPA.  Please include the EPA Docket ID Number [EPA-HQ-OPA-2007-0584] and OMB Control Number 2050-0021 in any correspondence.