Burden Tables

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Overview

Table 1
Table 2

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Sheet 1: Table 1

Table 1: Annual Respondent Burden and Cost – NSPS for Petroleum Refineries for which Construction, Reconstruction, or Modification Commenced after May 14, 2007 (40 CFR Part 60, Subpart Ja) (Renewal)
					103.97	123.93	51.79
Burden Item	(A) Person-hours per occurrence	(B) Number of occurrences per year per respondenta	(C) Person-hrs. per respondent per year (C=AxB)	(D) Respondents per yearb	(E) Technical person-hrs. per year (E=CxD)	(F) Management person‑hrs. per year (F=Ex0.05)	(G) Clerical person-hrs. per year (G=Ex0.1)	(H) Annual costs ($)c
1. Applications	N/A
2. Survey and Studies
A. Flare Management Plan	160	2.89	462.4	0	0	0	0	$0
B. Root Cause Analysis (flow)	45	4	180	150	27,000	1,350	2,700	$3,114,328.50
C. Root Cause Analysis (sulfur)	24	3	72	150	10,800	540	1,080	$1,245,731.40
3. Reporting Requirements
A. Familiarize with rule requirements	1	1	1	150	150	7.5	15	$17,301.8
B. Required Activities
Initial performance tests d	40	6	240	0	0	0	0	0
Repeat of performance tests e	40	0.2	8	0	0	0	0	0
CEMS Audits (RAA or CGA)	36	6	216	0	0	0	0	0
Initial Relative Accuracy Testf	24	3.97	95.28	0	0	0	0	0
CMS Audits (RAA or CGA)f	36	3.97	142.92	0	0	0	0	0
C. Create Information	See 3B
D. Gather Existing Information	See 3E
E. Write Reportg
Notification of construction, reconstruction, or modification	2	9.89	19.78	0	0	0	0	0
Notification of anticipated startup	2	9.89	19.78	0	0	0	0	0
Notification of actual startup	2	9.89	19.78	0	0	0	0	0
Notification of initial performance test	2	8.89	17.78	0	0	0	0	0
Report of performance test	See 3B
Semiannual Emissions Reportsh	16	2	32	150	4,800	240	480	$553,658.40
Subtotal for Reporting Requirements					49,163			$4,931,020
4. Recordkeeping Requirements
A. Familiarize with rule requirements	See 3A
B. Plan Activities	See 3B
C. Implement Activities	See 3B
D. Develop Record System	N/A
E. Time to Enter Information
Records of operating parametersi	0.25	350	87.5	150	13,125	656	1,313	$1,513,909.69
F. Train Personnel	N/A
G. Audits	N/A
Subtotal for Recordkeeping Requirements					15,094			$1,513,910
TOTAL LABOR BURDEN AND COST (roundedj)					64,300			$6,440,000
Capital and O&M Cost								$15,700,000
Grand TOTAL								$22,100,000
Assumptions
a Occurrences per respondent per year is calculated as the number of occurrences per source per year multiplied by the number of sources per respondent (refinery).
b Assume that there are approximately 150 plants (respondents) which become subject over a 3-year period. There will be no additional new source that will become subject to the rule over the three years of this ICR.
c This ICR uses the following labor rates: $129.93 per hour for Executive, Administrative, and Managerial labor; $103.97 per hour for Technical labor, and $51.79 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 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.
d We have assumed that it will take 40 hour for each respondent to perform initial performance tests. There are 6 CEM units at 18 plants (respondents).
e We have assumed that 20 percent of sources would have to repeat performance test due to failure.
f Assume that there are two monitors needed for each source, one to monitor sulfur content and one to monitor flow rate.
g We have assumed that each respondent will take 2 hours to write report.
h We have assumed that each respondent will take 8 hours twice per year to complete semiannual reports
i Assume operation 350 days per year as specified in the NSPS review document.
j Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 2: Table 2

Table 2: Average Annual EPA Burden and Cost – NSPS for Petroleum Refineries for which Construction, Reconstruction, or Modification Commenced after May 14, 2007(40 CFR part 60, subpart Ja) (Renewal)
					46.67	62.9	25.25
Activity	(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) Cost, $ b
New Plants:
Report Review
Notification of construction, reconstruction, or modificationc	2	2.89	5.78	0	0	0	0	$0
Notification of anticipated startupd	0.5	2.89	1.445	0	0	0	0	$0
Notification of actual startupd	0.5	2.89	1.445	0	0	0	0	$0
Notification of accuracy testd	0.5	1.98	0.99	0	0	0	0	$0
Flare management planse	1	2.89	2.89	0	0	0	0	$0
Review test results	8	1.98	15.84	0	0	0	0	$0
Emission Reports	4.2	2	8.4	0	0	0	0	$0
Existing Plants:
Semiannual Emissions Reportsf	4.2	2	8.4	150	1260	63	126	$65,948.40
TOTAL ANNUAL BURDEN AND COST (roundedg)					1,450			$65,900
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 (GS-13, Step 5, $39.31 x 1.6), $46.67 for Technical (GS-12, Step 1, $29.17 x 1.6) and $25.25 Clerical (GS-6, Step 3, $15.78 x 1.6). These rates are from the Office of Personnel Management (OPM) 2014 General Schedule, which excludes locality rates of pay.
c We have assumed that all existing new sources will take 2 hours to complete report.
d We have assumed that all existing sources will each take 0.5 hours to complete report.
e Some plans will need more review than others, depending on complexity of flare connections and baseline calculations; assume 1 hour is the average amount of time spent per plan.
f We have assumed that all existing plants will be required to complete semiannual emissions reports.
g Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.