1054ss12

SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NSPS for Petroleum Refineries (40 CFR Part 60, Subpart J) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NSPS for Petroleum Refineries (40 CFR Part 60, Subpart J) (Renewal), EPA ICR Number 1054.12, OMB Control Number 2060-0022.

1(b) Short Characterization/Abstract

The New Source Performance Standards (NSPS) for Petroleum Refineries were proposed on June 11, 1973, promulgated on March 8, 1974, and most recently amended on September 12, 2012. The amendment provided technical clarifications and allowed the option for affected sources to comply with Subpart J by following the requirements established in NSPS Subpart Ja rule. The affected sources are 1) fluid catalytic cracking unit (FCCU) catalyst regenerator or fuel gas combustion device (FGCD) other than a flare that commenced construction, reconstruction or modification after June 11, 1973 and on or before May 14, 2007; 2) FGCD that is also a flare that commenced construction, reconstruction or modification after June 11, 1973 and on or before June 24, 2008; or 3) any Claus sulfur recovery plant with a design capacity of more than 20 long tons per day sulfur feed which commenced construction, reconstruction or modification after October 4, 1976 and on or before May 14, 2007. This information is being collected to assure compliance with 40 CFR Part 60, Subpart J. (Note: Units that are constructed, reconstructed or modified after the end date of Subpart J applicability (e.g., May 14, 2007 for FGCDs other than a flare and June 24, 2008 for FGCD that is also a flare) are subject to the requirements under NSPS Subpart Ja. Under Subpart Ja, a “flare” is no longer a subcategory of FGCDs and EPA has established a separate suite of standards. At the time of this ICR renewal, all refinery flares are complying with the NSPS Subpart Ja requirements.)

In general, all NSPS standards require initial notifications, performance tests, and periodic reports by the owners/operators of the affected facilities. They are also required to maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an affected facility, or any period during which the monitoring system is inoperative. These notifications, reports, and records are essential in determining compliance, and are required of all affected facilities subject to NSPS.

Any owner/operator subject to the provisions of this part shall maintain a file of these measurements, and retain the file for at least two years following the date of such measurements, maintenance reports, and records. All reports are sent to the delegated state or local authority. In the event that there is no such delegated authority, the reports are sent directly to the United States Environmental Protection Agency (EPA) regional office.

Over the next three years, an average of 150 respondents per year will be subject to the standard, and no additional respondents per year will become subject to the standard.

The Office of Management and Budget (OMB) approved the currently active ICR without any “Terms of Clearance.”

In the United States, there are approximately 150 petroleum refineries that are publicly owned and operated by the petroleum refining industry. None of these facilities are owned by either state, local, tribal, or the Federal government. They are all owned and operated solely by privately-owned, for-profit businesses. The burden to the “Affected Public” may be found in Table 1: Annual Respondent Burden and Cost – NSPS for Petroleum Refineries (40 CFR Part 60, Subpart J) (Renewal). The “Federal Government” burden is attributed entirely to work performed by federal employees or government contractors and may be found in Table 2: Average Annual EPA Burden and Cost – NSPS for Petroleum Refineries (40 CFR Part 60, Subpart J) (Renewal).

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under Section 111 of the Clean Air Act (CAA), as amended, to establish standards of performance for new stationary sources that reflect:

. . . application of the best technological system of continuous emissions reduction which (taking into consideration the cost of achieving such emissions reduction, or any non-air quality health and environmental impact and energy requirements) the Administrator determines has been adequately demonstrated. Section 111(a)(l).

The Agency refers to this charge as selecting the best demonstrated technology (BDT). Section 111 also requires that the Administrator review and, if appropriate, revise such standards every four years. In addition, section 114(a) states that the Administrator may require any owner/operator subject to any requirement of this Act to:

(A) Establish and maintain such records; (B) make such reports; (C) install, use, and maintain such monitoring equipment, and use such audit procedures, or methods; (D) sample such emissions (in accordance with such procedures or methods, at such locations, at such intervals, during such periods, and in such manner as the Administrator shall prescribe); (E) keep records on control equipment parameters, production variables or other indirect data when direct monitoring of emissions is impractical; (F) submit compliance certifications in accordance with Section 114(a)(3); and (G) provide such other information as the Administrator may reasonably require.

In the Administrator's judgment, particulate matter, carbon monoxide, and sulfur oxide emissions from petroleum refineries cause or contribute to air pollution that may reasonably be anticipated to endanger public health or welfare. Therefore, the NSPS were promulgated for this source category at 40 CFR Part 60, Subpart J.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensure compliance with the applicable regulations which were promulgated in accordance with the Clean Air Act. The collected information is also used for targeting inspections and as evidence in legal proceedings.

Performance tests are required in order to determine an affected facility’s initial capability to comply with the emission standard. Continuous emission monitors are used to ensure compliance with the standard at all times. During the performance test a record of the operating parameters under which compliance was achieved may be recorded and used to determine compliance in place of a continuous emission monitor.

The notifications required in the standard are used to inform the Agency or delegated authority when a source becomes subject to the requirements of the regulations. The reviewing authority may then inspect the source to check if the pollution control devices are properly installed and operated, leaks are being detected and repaired, and the standard are being met. The performance test may also be observed.

The required semiannual reports are used to determine periods of excess emissions, identify problems at the facility, verify operation/maintenance procedures and for compliance determinations.

3. Nonduplication, Consultations, and Other Collection Criteria

3(a) Nonduplication

If the subject standards have not been delegated, the information is sent directly to the appropriate EPA regional office. Otherwise, the information is sent directly to the delegated state or local agency. If a state or local agency has adopted its own similar standards to implement the Federal standards, a copy of the report submitted to the state or local agency can be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, no duplication exists.

3(b) Public Notice Required Prior to ICR Submission to OMB

An announcement of a public comment period for the renewal of this ICR was published in the Federal Register (79 FR 30117) on May 27, 2014. No comments were received on the burden published in the Federal Register.

3(c) Consultations

The Agency’s industry experts have been consulted, and the Agency’s internal data sources and projections of industry growth over the next three years have been considered. The primary source of information as reported by industry, in compliance with the recordkeeping and reporting provisions in the standard, is the Online Tracking Information System (OTIS) which is operated and maintained by EPA's Office of Compliance. OTIS is EPA’s database for the collection, maintenance, and retrieval of all compliance data. The growth rate for the industry is based on our consultations with the Agency’s internal industry experts.

Industry trade associations and other interested parties were provided an opportunity to comment on the burden associated with the standard as it was being developed and the standard has been previously reviewed to determine the minimum information needed for compliance purposes. In developing this ICR, we contacted both the American Petroleum Industry at (202) 682-8209 and the American Fuel & Petrochemical Manufacturers (AFPM) at (202) 457-0480.

It is our policy to respond after a thorough review of comments received since the last ICR renewal as well as those submitted in response to the first Federal Register notice. In this case, no comments were received.

3(d) Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of assurance that facilities are continuing to meet the standards. Requirements for information gathering and recordkeeping are useful techniques to ensure that good operation and maintenance practices are applied and emission limitations are met. If the information required by these standards was collected less frequently, the proper operation and maintenance of control equipment and the possibility of detecting violations would be less likely.

3(e) General Guidelines

These reporting or recordkeeping requirements do not violate any of the regulations promulgated by OMB under 5 CFR Part 1320, Section 1320.5.

3(f) Confidentiality

Any information submitted to the Agency for which a claim of confidentiality is made will be safeguarded according to the Agency policies set forth in Title 40, chapter 1, part 2, subpart B - Confidentiality of Business Information (see 40 CFR 2; 41 FR 36902, September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979).

3(g) Sensitive Questions

The reporting or recordkeeping requirements in the standard do not include sensitive questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are owners and operators of petroleum refineries. The United States Standard Industrial Classification (SIC) code for the respondents affected by the standards is SIC 2911, which corresponds to the North American Industry Classification System (NAICS) code 324110 for Petroleum Refineries.

4(b) Information Requested

(i) Data Items

In this ICR, all the data that is recorded or reported is required by the NSPS for Petroleum Refineries (40 CFR Part 60, Subpart J).

A source must make the following reports:

Notifications
Notification of the actual date of initial startup, and notification of specific provisions for sulfur dioxide (SO2) standards with which the source seeks to comply	60.7(a)(3),60.1079(a)
Notification of performance test and of any relevant delays.	60.8(d)
Notification of the date of construction (or reconstruction).	60.7(a)(1)
Notification of any physical or operational change to an existing facility, which may increase the emission rate of any air pollution to which a standard applies.	60.7(a)(4)
Notification of the date upon which demonstration of the continuous monitoring system performance commences.	60.7(a)(5)
Notification of the anticipated date for conducting the opacity observations, including, if appropriate, a request for the Administrator to provide a visible emissions reader during a performance test.	60.7(a)(6)
Notification that Continuous Opacity Monitoring System (COMS) will be used during a performance test in lieu of Method 9 observation data.	60.7(a)(7)
Request for exemption from the carbon monoxide (CO) continuous monitoring system requirements.	60.105(a)(2)(ii)
Notification of change in semiannual report due to change in SO2 compliance method.	60.108(e)

Reports
Results of performance tests including opacity observations and results.	60.8(a), 0.11(e)(2-6) 60.13(c)
Semiannual reports.	60.107(c),(e-f)
Reports of any periods for which SO2 or oxides emissions data are not available.	60.107(c-f)
Report of any periods for which SO2 or oxides emissions data are not available.	60.107(d)
Excess emissions and monitoring systems performance report and/or summary report (to be submitted with semiannual report).	60.7(c-d), 60.105(e)

A source must keep the following records:

Recordkeeping
Records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an affected facility; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring device is inoperative.	60.7(b)
Daily records of the average coke-burn-off rate and hours of operation for any fluid catalytic cracking unit catalyst regenerator.	60.105(c)
Daily records of the rate of combustions of liquid or solid fossil-fuels and the hours of operation during which they are combusted in the incinerator-waste heat boiler (applies to fluid catalytic cracking unit catalysts regenerators that use incinerator-waste heat boilers).	60.105(d)
Records of data obtained from the daily feed sulfur tests (if complying with 60.104(b)(3).	60.107(b)(3)
Records of each 7-day rolling average compliance determination.	60.107(b)(4)
Records of COMS results during initial performance test.	60.11(e)(4)
Records of all data and calibrations from continuous monitoring systems, including results of daily drift tests and quarterly accuracy assessments; measurements obtained by supplemental sampling for meeting minimum data requirements and written procedures for the quality control program (if complying with 60.104(b)(1)).	60.107(b)(1)
Records of measurements obtained in the daily Method 8 testing, or those obtained by alternative measurements, if applicable (complying with 60.104(b)(2).	60.107(b)(2)
Records of all measurements, including continuous monitoring system, monitoring device, and performance testing measurements; all continuous monitoring system performance evaluations; all continuous monitoring system or monitoring device calibration checks; and adjustments and maintenance performed on these systems or devices.	60.7(f)

Electronic Reporting

Some of the respondents are using monitoring equipment that automatically records parameter data. Although personnel at the affected facility must still evaluate the data, internal automation has significantly reduced the burden associated with monitoring and recordkeeping at a plant site.

Also, regulatory agencies in cooperation with the respondents continue to create reporting systems to transmit data electronically. However, electronic reporting systems are still not widely used. At this time, it is estimated that approximately 70 percent of the respondents use electronic reporting.

(ii) Respondent Activities

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate CMS for opacity, CO, SO_2, and O₂.

Perform initial performance test, Reference Method 5B or 5F; 9; 6; 15; 3 or 3A; 8; 3; 6, 6B, or 8 test, and repeat performance tests if necessary.

Write the notifications and reports listed above.

Enter information required to be recorded above.

Submit the required reports developing, acquiring, installing, and utilizing technology and systems for the purpose of collecting, validating, and verifying information.

Develop, acquire, install, and utilize technology and systems for the purpose of processing and maintaining information.

Develop, acquire, install, and utilize technology and systems for the purpose of disclosing and providing information.

Train personnel to be able to respond to a collection of information.

Transmit, or otherwise disclose the information.

Currently sources are using monitoring and reporting equipment that provide parameter data in an automated way, e.g., continuous parameter monitoring system. Although personnel at the source still need to evaluate the data, this type of monitoring equipment has significantly reduced the burden associated with monitoring and recordkeeping.

5. The Information Collected: Agency Activities, Collection Methodology, and Information Management

5(a) Agency Activities

EPA conducts the following activities in connection with the acquisition, analysis, storage, and distribution of the required information.

Agency Activities

Review notifications and reports, including performance test reports, and excess emissions reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the Online Tracking Information System (OTIS).

5(b) Collection Methodology and Management

Following notification of startup, the reviewing authority could inspect the source to determine whether the pollution control devices are properly installed and operated. Performance test reports are used by the Agency to discern a source’s initial capability to comply with the emission standard and note the operating conditions under which compliance was achieved. Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs. The semiannual reports are used for problem identification, as a check on source operation and maintenance, and for compliance determinations.

Information contained in the reports is entered into OTIS which is operated and maintained by EPA's Office of Compliance. OTIS is EPA’s database for the collection, maintenance, and retrieval of compliance data for approximately 125,000 industrial and government-owned facilities. EPA uses the OTIS for tracking air pollution compliance and enforcement by local and state regulatory agencies, EPA regional offices and EPA headquarters. EPA and its delegated Authorities can edit, store, retrieve and analyze the data.

The records required by this regulation must be retained by the owner/operator for two years.

5(c) Small Entity Flexibility

A majority of the respondents are large entities (i.e., large businesses). However, the impact on small entities (i.e., small businesses) was taken into consideration during the development of the regulation. Due to technical considerations involving the process operations and the types of control equipment employed, the recordkeeping and reporting requirements are the same for both small and large entities. The Agency considers these to be the minimum requirements needed to ensure compliance and, therefore, cannot reduce them further for small entities. To the extent that larger businesses can use economies of scale to reduce their burden, the overall burden will be reduced.

5(d) Collection Schedule

The specific frequency for each information collection activity within this request is shown in below Table 1: Annual Respondent Burden and Cost – NSPS for Petroleum Refineries (40 CFR Part 60, Subpart J) (Renewal).

6. Estimating the Burden and Cost of the Collection

Table 1 documents the computation of individual burdens for the recordkeeping and reporting requirements applicable to the industry for the subpart included in this ICR. The individual burdens are expressed under standardized headings believed to be consistent with the concept of burden under the Paperwork Reduction Act. Where appropriate, specific tasks and major assumptions have been identified. Responses to this information collection are mandatory.

The 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.

6(a) Estimating Respondent Burden

The average annual burden to industry over the next three years from these recordkeeping and reporting requirements is estimated to be 15,784 (Total Labor Hours from Table 1). These hours are based on Agency studies and background documents from the development of the regulation, Agency knowledge and experience with the NSPS program, the previously approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates:

Managerial $128.02 ($60.98 + 110%)

Technical $101.05 ($48.12 + 110%)

Clerical $51.37 ($24.46 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2014, “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 the benefit packages available to those employed by private industry.

(ii) Estimating Capital/Startup and Operation and Maintenance Costs

The type of industry costs associated with the information collection activities in the subject standard are both labor costs which are addressed elsewhere in this ICR and the costs associated with continuous monitoring. The capital/startup costs are one time costs when a facility becomes subject to the regulation. The annual operation and maintenance costs are the ongoing costs to maintain the monitors and other costs such as photocopying and postage.

(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs

Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A) Continuous Monitoring Device	(B) Capital/Startup Cost for One Respondent	(C) Number of New Respondents	(D) Total Capital/Startup Cost, (B X C)	(E) Annual O&M Costs for One Respondent	(F) Number of Respondents with O&M	(G) Total O&M, (E X F)
Opacity	$26,056	0	$0	$1,303	150	$195,450
CO	8,848	0	$0	$885	150	$132,750
SO2/H2S	13,028	0	$0	$1,303	150	$195,450
O2	6,107	0	$0	$1,303	150	$195,450
Total			$0			$719,100

The total capital/startup costs for this ICR are zero. This is the total of column D in the above table.

The total operation and maintenance (O&M) costs for this ICR are $719,100. This is the total of column G.

The average annual cost for capital/startup and operation and maintenance costs to industry over the next three years of the ICR is estimated to be $719,100.

6(c) Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of the reported information. EPA's overall compliance and enforcement program includes activities such as the examination of records maintained by the respondents, periodic inspection of sources of emissions, and the publication and distribution of collected information.

The average annual Agency cost during the three years of the ICR is estimated to be $23,553.

This cost is based on the average hourly labor rate as follows:

Managerial $62.90 (GS-13, Step 5, $39.31 + 60%)

Technical $46.67 (GS-12, Step 1, $29.17 + 60%)

Clerical $25.25 (GS-6, Step 3, $15.78 + 60%)

These rates are from the Office of Personnel Management (OPM), 2014 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. Details upon which this estimate is based appear below in Table 2: Average Annual EPA Burden and Cost – NSPS for Petroleum Refineries (40 CFR Part 60, Subpart J) (Renewal).

6(d) Estimating the Respondent Universe and Total Burden and Costs

Based on our research for this ICR, on average over the next three years, approximately 150 existing respondents will be subject to the standard. It is estimated that no additional respondents per year will become subject. The overall average number of respondents, as shown in the table below, is 150 per year.

The number of respondents is calculated using the following table that addresses the three years covered by this ICR.

Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
Year	(A) Number of New Respondents 1	(B) Number of Existing Respondents	(C) Number of Existing Respondents that keep records but do not submit reports	(D) Number of Existing Respondents That Are Also New Respondents	(E) Number of Respondents (E=A+B+C-D)
1	0	150	0	0	150
2	0	150	0	0	150
3	0	150	0	0	150
Average	0	150	0	0	150

¹ New respondents include sources with constructed, reconstructed and modified affected facilities.

Column D is subtracted to avoid double-counting respondents. As shown above, the average Number of Respondents over the three year period of this ICR is 150.

The total number of annual responses per year is calculated using the following table:

Total Annual Responses
(A) Information Collection Activity	(B) Number of Respondents	(C) Number of Responses	(D) Number of Existing Respondents That Keep Records But Do Not Submit Reports	(E) Total Annual Responses E=(BxC)+D
Notification of construction or modification	0	1	0	0
Notification of performance test	0	1	0	0
Report of performance test	0	1	0	0
Semiannual report	150	2	0	300
			Total	300

The number of Total Annual Responses is 150.

The total annual labor costs are $1,545,270. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost – NSPS for Petroleum Refineries (40 CFR Part 60, Subpart J) (Renewal).

6(e) Bottom Line Burden Hours and Cost Tables

The detailed bottom line burden hours and cost calculations for the respondents and the Agency are shown in Tables 1 and 2, respectively, and summarized below.

(i) Respondent Tally

The total annual labor hours are 15,784. Details regarding these estimates may be found in Table 1: Annual Respondent Burden and Cost – NSPS for Petroleum Refineries (40 CFR Part 60, Subpart J) (Renewal).

Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 53 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $719,100. The cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M) Costs.

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is estimated to be 518 labor hours at a cost of $23,553. See Table 2: Average Annual EPA Burden and Cost – NSPS for Petroleum Refineries (40 CFR Part 60, Subpart J) (Renewal).

6(f) Reasons for Change in Burden

There is no change in the respondent labor hours in this ICR compared to the previous ICR since the 2012 rule amendments did not require additional monitoring, recordkeeping and reporting requirements under NSPS J. Modified or reconstructed sources under NSPS Subpart J would trigger NSPS Subpart Ja applicability. However, there is an increase in the estimated burden costs. The increase is not due to any program changes; rather, it is due to the use of updated labor rates. There is also a small increase in the Agency labor hours and cost due to a mathematical correction.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is estimated to average 53 hours per response. 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 valid OMB Control Number. The OMB Control Numbers for EPA regulations are listed at 40 CFR Part 9 and 48 CFR Chapter 15.

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-OECA-2014-0033. An electronic version of the public docket is available at http://www.regulations.gov/ which may be used to obtain a copy of the draft collection of information, submit or view public comments, access the index listing of the contents of the 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 in this document. The documents are also available for public viewing at the Enforcement and Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Ave., NW, Washington, DC. 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 (202) 566-1744, and the telephone number for the docket center is (202) 566-1927. Also, you can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA-HQ-OECA-2014-0033 and OMB Control Number 2060-0022 in any correspondence.

Part B of the Supporting Statement

This part is not applicable because no statistical methods were used in collecting this information.

Table 1: Annual Respondent Burden and Cost – NSPS for Petroleum Refineries (40 CFR Part 60, Subpart J) (Renewal)

Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical person- hours per year (E=CxD)	(F) Management person hours per year (Ex0.05)	(G) Clerical person hours per year (Ex0.1)	(H) Total Cost per year b
1. Applications	N/A
2. Survey and Studies	N/A
3. Reporting requirements
A. Read instructions c	1	1	1	0	0	0	0	$0
B. Required activities
Performance Tests
a.   Relative Accuracy Test d	146	1	146	0	0	0	0	$0
b.  CEMS audits (RAA or CGA) e	160	2	320	0	0	0	0	$0
C. Create information	See 3B
D. Gather existing information	See 3B
E. Write Reports
Notification of construction /reconstruction f	2	1	2	0	0	0	0	$0
ii Notification of performance test f	2	1	2	0	0	0	0	$0
iii. Report of performance test f	2	1	2	0	0	0	0	$0
iv. Semiannual emission reports g	2	2	4	150	600	30	60	$67,552.80
Subtotal for Reporting Requirements					690			$67,552.80
4. Recordkeeping requirements
A. Read instructions	See 3A
B. Plan activities	See 3A
C. Implement Activities	See 3B
D. Develop record system	N/A
E. Time to enter information
Records of Operating Parameters h	0.25	350	87.5	150	13,125	656.25	1,312.5	$1,477,717.50
F. Time to train personnel	N/A
G. Time for audits	N/A
Subtotal for Recordkeeping Requirements					15,094			$1,477,717.50
TOTAL LABOR BURDEN AND COST (rounded)					15,784			$1,545,270

Assumptions:

^a We have assumed that there are approximately 150 respondents, with no additional new, modified or reconstructed sources becoming subject to NSPS Subpart J over the next three years since any of these events would trigger Subpart Ja applicability.

^b This ICR uses the following labor rates: $128.02 per hour for Executive, Administrative, and Managerial labor; $101.05 per hour for Technical labor, and $51.37 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2014, Table 2. Civilian Workers, by Occupational and Industry groups. The rates are from column 1, Total Compensation. The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry.

^c We have assumed that it will take one hour for each respondent to read instructions.

^d We have assumed that it will take 146 hours for each respondent to perform the relative active tests once per year.

^e We have assumed that it will take 160 hours for each respondent to perform CEMS audits twice per year.

^f We have assumed that it will take two hour for each respondent to write reports once per year.

^g We have assumed that it will take two hours for each respondent to write semiannual emissions reports twice per year.

^h We have assumed that each respondent will take 0.25 hours 350 days per year to enter records of operating parameters.

Table 2: Average Annual EPA Burden and Cost – NSPS for Petroleum Refineries (40 CFR Part 60, Subpart J) (Renewal)

Activity	(A) EPA person-hours per occurrence	(B) No. of occurrences per plant per year	(C) EPA person hours per plant per year (AxB)	(D) Plants per year a	(E) Technical person-hours per year (CxD)	(F) Management person-hours per year (Ex0.05)	(G) Clerical person-hours per year (Ex0.1)	(H) Cost, $ b
1. Review reports
a.       Notification of construction/reconstruction c	0.5	1	0.5	0	0	0	0	$0
b.       Notification of performance test d	0.5	1	0.5	0	0	0	0	$0
c.        Semiannual emission reports e	1.5	2	3	150	450	22.5	45	$23,553.00
TOTAL ANNUAL BURDEN AND COST (rounded)					518			$23,553

Assumptions:

^a We have assumed that there are approximately 150 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next

three years.

^b This cost is based on the following hourly labor rates times a 1.6 benefits multiplication factor to account for government overhead expenses: $62.90 for Managerial, $46.67 for Technical, and $25.25 for Clerical. These rates are from the Office of Personnel Management (OPM) “2014 General Schedule” which excludes locality rates of pay.

^c We have assumed that it will take 0.5 hours once a year for each respondent to review report.

^d We have assumed that it will take 0.5 hours once a year for each respondent to review performance test report.

^e We have assumed that it will take 1.5 hours, twice per year, for each respondent to review the excess emission reports.