| Table 1. Annual Respondent Burden and Cost - NESHAP for Petroleum Refineries (40 CFR Part 63, Subpart CC) (Renewal) |
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112.01 |
64.74 |
66.49 |
139.63 |
43.47 |
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| Burden item |
(A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
(H) |
(I) |
(J) |
| Person-hours per occurrence |
No. of occurrences per respondent per year |
Person-hours per respondent per year
(C=AxB) |
Respondents per year a |
Technical person-hours per year
(E=CxD) |
Installation, maintenance, and repair person-hours per year
(F=CxD) |
Plant operator person-hours per year
(G=CxD) |
Management person-hours per year
(Ex0.05) |
Clerical person hours per year
(Ex0.1) |
Cost b $ |
| 1. Applications |
N/A |
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| 2. Survey and studies |
N/A |
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| 3. Acquisition, installation, and utilization of technology and systems c |
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| Technical |
32 |
1 |
32 |
0 |
0 |
N/A |
N/A |
0 |
0 |
$0.00 |
| Management |
2 |
1 |
2 |
0 |
0 |
N/A |
N/A |
0 |
0 |
$0.00 |
| 4. Reporting requirements |
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| A. Read and understand rule requirementsd, e |
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| Initial: |
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| i. General/applicability |
20 |
0.1 |
2 |
142 |
284 |
N/A |
N/A |
14.2 |
28.4 |
$35,028.13 |
| ii. Storage vessels |
20 |
0.9 |
18 |
142 |
2556 |
N/A |
N/A |
127.8 |
255.6 |
$315,253.21 |
| iii. Process units – LDAR |
20 |
1.1 |
22 |
142 |
3124 |
N/A |
N/A |
156.2 |
312.4 |
$385,309.47 |
| iv. Process vents |
20 |
0.9 |
18 |
142 |
2556 |
N/A |
N/A |
127.8 |
255.6 |
$315,253.21 |
| Periodic: |
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| i. General/applicability |
4 |
1 |
4 |
142 |
568 |
N/A |
N/A |
28.4 |
56.8 |
$70,056.27 |
| ii. Storage vessels |
1 |
9 |
9 |
142 |
1278 |
N/A |
N/A |
63.9 |
127.8 |
$157,626.60 |
| iii. Process units – LDAR |
2 |
11 |
22 |
142 |
3124 |
N/A |
N/A |
156.2 |
312.4 |
$385,309.47 |
| iv. Process vents |
2 |
9 |
18 |
142 |
2556 |
N/A |
N/A |
127.8 |
255.6 |
$315,253.21 |
| v. Heat exchange systems |
2 |
3 |
6 |
142 |
852 |
N/A |
N/A |
42.6 |
85.2 |
$105,084.40 |
| B. Required activities d, e |
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| Initial: |
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| i. General/applicability |
10 |
0.1 |
1 |
142 |
142 |
N/A |
N/A |
7.1 |
14.2 |
$17,514.07 |
| ii. Storage vessels |
88 |
0.9 |
79.2 |
142 |
11246.4 |
N/A |
N/A |
562.32 |
1124.64 |
$1,387,114.11 |
| iii. Process units – LDAR |
8 |
1.1 |
8.8 |
142 |
1249.6 |
N/A |
N/A |
62.48 |
124.96 |
$154,123.79 |
| iv. Process vents – initial performance test f |
11 |
0.4 |
4.4 |
142 |
624.8 |
N/A |
N/A |
31.24 |
62.48 |
$77,061.89 |
| v. Process vents – repeat performance test f |
11 |
0.4 |
4.4 |
71 |
312.4 |
N/A |
N/A |
15.62 |
31.24 |
$38,530.95 |
| Periodic: |
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| i. General/applicability |
3 |
1 |
3 |
142 |
426 |
N/A |
N/A |
21.3 |
42.6 |
$52,542.20 |
| ii. Storage vessels |
4 |
9 |
36 |
142 |
5112 |
N/A |
N/A |
255.6 |
511.2 |
$630,506.41 |
| iii. Process units – LDAR |
1 |
11 |
11 |
142 |
1562 |
N/A |
N/A |
78.1 |
156.2 |
$192,654.74 |
| iv. Process vents |
2 |
9 |
18 |
142 |
2556 |
N/A |
N/A |
127.8 |
255.6 |
$315,253.21 |
| v. Heat exchange systems – sampling analysis g |
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| Technical |
1 |
36 |
36 |
142 |
5112 |
N/A |
N/A |
N/A |
N/A |
$572,595.12 |
| Plant operator |
3 |
36 |
108 |
142 |
N/A |
N/A |
15336 |
N/A |
N/A |
$1,019,690.64 |
| vi. Heat exchange systems – triggered monitoring of leak h |
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| Technical |
1 |
2 |
2 |
142 |
284 |
N/A |
N/A |
N/A |
N/A |
$31,810.84 |
| Plant operator |
3 |
2 |
6 |
142 |
N/A |
N/A |
852 |
N/A |
N/A |
$56,649.48 |
| vii. Heat exchange systems – leak repair i |
40 |
2 |
80 |
142 |
N/A |
11360 |
N/A |
N/A |
N/A |
$735,446.40 |
| C. Create information |
See 4B |
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| D. Gather existing information |
See 4B |
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| E. Write report d, e |
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| Startup, shutdown, and malfunction plan |
40 |
1 |
40 |
0 |
0 |
N/A |
N/A |
0 |
0 |
$0.00 |
| Notification of compliance status j |
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| i. Storage vessels |
1 |
0.9 |
0.9 |
142 |
127.8 |
N/A |
N/A |
6.39 |
12.78 |
$15,762.66 |
| ii. Process units – LDAR |
4 |
1.1 |
4.4 |
142 |
624.8 |
N/A |
N/A |
31.24 |
62.48 |
$77,061.89 |
| iii. Process vents |
1 |
0.9 |
0.9 |
142 |
127.8 |
N/A |
N/A |
6.39 |
12.78 |
$15,762.66 |
| iv. Heat exchange systems |
1 |
0.3 |
0.3 |
142 |
42.6 |
N/A |
N/A |
2.13 |
4.26 |
$5,254.22 |
| Notification of storage vessel inspections |
1 |
0.9 |
0.9 |
142 |
127.8 |
N/A |
N/A |
6.39 |
12.78 |
$15,762.66 |
| Notification of reconstruction – process vent control devices f |
4 |
0.4 |
1.6 |
142 |
227.2 |
N/A |
N/A |
11.36 |
22.72 |
$28,022.51 |
| Notification of performance tests d, e |
See 4B |
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| Startup, shutdown, and malfunction reports |
See semiannual compliance reports |
| Semiannual compliance reports k, l |
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| i. General/applicability m |
18 |
2 |
36 |
142 |
5112 |
N/A |
N/A |
255.6 |
511.2 |
$630,506.41 |
| ii. Storage vessels n |
1 |
18 |
18 |
142 |
2556 |
N/A |
N/A |
127.8 |
255.6 |
$315,253.21 |
| iii. Storage vessels – seal gap failure o |
3 |
2 |
6 |
142 |
852 |
N/A |
N/A |
42.6 |
85.2 |
$105,084.40 |
| iv. Process units – LDAR p |
3 |
22 |
66 |
142 |
9372 |
N/A |
N/A |
468.6 |
937.2 |
$1,155,928.42 |
| v. Process vents q |
1.5 |
8 |
12 |
142 |
1704 |
N/A |
N/A |
85.2 |
170.4 |
$210,168.80 |
| vi. Heat exchange systems r |
2 |
6 |
12 |
142 |
1704 |
N/A |
N/A |
85.2 |
170.4 |
$210,168.80 |
| Reporting Subtotal |
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105,057 |
$10,150,404.47 |
| 5. Recordkeeping requirements |
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| A. Read and understand rule requirements |
See 4A |
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| B. Plan activities d, e |
See 4A |
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| C. Implement activities d, e |
See 4B |
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| D. Develop record system s |
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| Initial: |
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| i. Storage vessels |
2 |
0.9 |
1.8 |
142 |
255.6 |
N/A |
N/A |
12.78 |
25.56 |
$31,525.32 |
| ii. Process units – LDAR |
75 |
1.1 |
82.5 |
142 |
11715 |
N/A |
N/A |
585.75 |
1171.5 |
$1,444,910.53 |
| iii. Process vents |
2 |
0.9 |
1.8 |
142 |
255.6 |
N/A |
N/A |
12.78 |
25.56 |
$31,525.32 |
| Periodic: |
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| i. Storage vessels |
2 |
9 |
18 |
142 |
2556 |
N/A |
N/A |
127.8 |
255.6 |
$315,253.21 |
| ii. Process units – LDAR |
75 |
11 |
825 |
142 |
117150 |
N/A |
N/A |
5857.5 |
11715 |
$14,449,105.28 |
| iii. Process vents |
2 |
9 |
18 |
142 |
2556 |
N/A |
N/A |
127.8 |
255.6 |
$315,253.21 |
| iv. Heat exchange systems t |
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| Technical |
12 |
12 |
144 |
142 |
20448 |
N/A |
N/A |
N/A |
N/A |
$2,290,380.48 |
| Plant operator |
12 |
12 |
144 |
142 |
N/A |
N/A |
20448 |
N/A |
N/A |
$1,359,587.52 |
| E. Time to enter and transmit information |
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| Initial: |
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| i. Storage vessels |
6 |
0.9 |
5.4 |
142 |
766.8 |
N/A |
N/A |
38.34 |
76.68 |
$94,575.96 |
| ii. Process units – LDAR |
99 |
1.1 |
108.9 |
142 |
15463.8 |
N/A |
N/A |
773.19 |
1546.38 |
$1,907,281.90 |
| iii. Process vents |
12 |
0.4 |
4.8 |
142 |
681.6 |
N/A |
N/A |
34.08 |
68.16 |
$84,067.52 |
| Periodic: u |
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| i. Storage vessels |
3.5 |
9 |
31.5 |
142 |
4473 |
N/A |
N/A |
223.65 |
447.3 |
$551,693.11 |
| ii. Process units – LDAR |
99 |
11 |
1089 |
142 |
154638 |
N/A |
N/A |
7731.9 |
15463.8 |
$19,072,818.96 |
| iii. Process vents |
29 |
4 |
116 |
142 |
16472 |
N/A |
N/A |
823.6 |
1647.2 |
$2,031,631.77 |
| iv. Heat exchange systems |
1 |
3 |
3 |
142 |
426 |
N/A |
N/A |
21.3 |
42.6 |
$52,542.20 |
| F. Time to train personnel v |
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| Initial: |
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| i. Storage vessels |
1 |
0.9 |
0.9 |
142 |
127.8 |
N/A |
N/A |
6.39 |
12.78 |
$15,762.66 |
| ii. Process units – LDAR |
1 |
1.1 |
1.1 |
142 |
156.2 |
N/A |
N/A |
7.81 |
15.62 |
$19,265.47 |
| iii. Process vents |
1 |
0.4 |
0.4 |
142 |
56.8 |
N/A |
N/A |
2.84 |
5.68 |
$7,005.63 |
| Periodic: |
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| i. Storage vessels |
N/A |
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|
| ii. Process units – LDAR |
0.5 |
11 |
5.5 |
142 |
781 |
N/A |
N/A |
39.05 |
78.1 |
$96,327.37 |
| iii. Process vents |
1 |
4 |
4 |
142 |
568 |
N/A |
N/A |
28.4 |
56.8 |
$70,056.27 |
| iv. Heat exchange systems w |
2 |
10 |
20 |
142 |
2840 |
N/A |
N/A |
142 |
284 |
$350,281.34 |
| Recordkeeping subtotal |
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422,626 |
$44,590,851 |
| TOTAL LABOR BURDEN AND COST (Rounded)x |
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528,000 |
$54,700,000 |
| Annualized cost of capital y |
$0 |
| Operation and maintenance (O&M) x,z |
$143,000 |
| TOTAL ANNUAL COST (Labor, Annualized Capital, O&M) x |
$54,800,000 |
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| Assumptions: |
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| a. We estimate there are 142 existing petroleum refineries in the U.S. subject to NESHAP subpart CC, based on recent Agency data gathered through an ICR collection request under Section 114 of the CAA. We assume that no new refineries will become subject to this regulation. Furthermore, we estimate that a refinery has the following affected units: 9 storage vessels; 11 process units subject to LDAR provisions; 9 process vents requiring monitoring, recordkeeping, and reporting; and 3 heat exchange systems subject to a monthly sampling program for VOC leak detection and repair, as well as recordkeeping and reporting requirements to ensure compliance with the program. |
| b. This ICR uses the following labor rates: $112.01 per hour for technical labor; $64.74 per hour for installation, maintenance, and repair; $66.49 per hour for plant operators; $139.63 per hour for executive, administrative, and managerial labor; and $43.47 per hour for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, "May 2014 National Industry-Specific Occupational Employment Wage Estimates" for NAICS code 324100 - Petroleum and Coal Products Manufacturing. The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry. |
| c. The labor estimates are based on an EPA Maximum Achievable Control Technology (MACT) floor cost analysis, which estimates the planning burden for a single heat exchange system to be 32 hours for technical labor and 2 labor hours for management. |
| d. We assume that initial notifications and periodic reporting requirements for existing sources are accounted for in other existing NSPS and NESHAP regulations for equipment leaks, wastewater, storage tanks, and heat exchangers. This ICR only addresses the additional industry burden associated with rule requirements for the compliance reports. |
| e. We assume that all existing respondents have complied with initial monitoring, recordkeeping, and reporting requirements for existing units, including initial notifications; design analysis and establishment of operating parameters for storage vessels; LDAR initial requirements; initial performance testing for process vents routed to a control device; heat exchanger requirements; and development of startup and malfunction plans and record systems for each unit. Respondents having reconstructed units, however, must comply with initial requirements. We estimate that existing refineries will reconstruct 10 percent of their existing units (i.e., 0.9 storage vessels, 1.1 process units, 0.9 process vents, and 0.3 heat exchange systems per refinery). |
| f. We assume that 4 process vents per refinery are routed to control devices, and of which existing refineries will reconstruct 10 percent. Also, we assume that 50 percent of respondents will repeat performance tests. |
|
DWang:
The 2013 has a provision for an alternate monitoring frequency (1/quarter at a lower leak action level).
g. We assume all heat exchange systems at existing refineries are in compliance with the heat exchange system monitoring requirements promulgated in the 2009 rule amendment, but would need to meet the periodic requirements. We estimate the labor burden for setup of portable air stripping column and sampling/analysis for one heat exchange system to be 1 hour for technical labor and 3 labor hours for an operator. We assume there are 3 heat exchange systems per refinery, and that the event occurs 12 times per system per year, for a total of 36 occurrences per refinery per year. |
| h. We assume 2 events per year at each refinery, and estimate the labor burden for additional sampling and analysis triggered by leak monitoring to be 1 hour for technical labor and 3 labor hours for an operator. |
| i. We assume 2 events per year at each refinery, and estimate the labor burden to be 40 hours per repair. |
| j. New and existing refineries must submit notifications of compliance status for new or reconstructed units affected by the standard. |
| k. The rule requires that sources meet specific periodic requirements including: monitoring of storage vessels annually, LDAR monitoring of process units daily, monthly monitoring of process vents, recording of process parameters and monitoring results, and submittal of periodic semiannual compliance reports addressing each affected facility and performance test result. |
| l. Notifications related to construction/reconstruction and to periodic reporting for existing sources are accounted for in other existing NSPS and NESHAP regulations for equipment leaks, wastewater, storage tanks, and heat exchangers. |
| m. We assume 18 labor hours per occurrence, and that there will be 2 occurrences per refinery per year. |
| n. We assume 1 labor hour per occurrence, and that there will be 18 occurrences per respondent per year (9 storage vessels/refinery x 2 occurrences/storage vessel/year). |
| o. We assume 3 labor hours per occurrence, and that there will be 2 occurrences per refinery per year. |
| p. We assume 3 labor hours per occurrence, and that there will be 22 occurrences per respondent per year (11 process units/refinery x 2 occurrences/process unit/year). |
| q. We assume 1.5 labor hours per occurrence, and that there will be 8 occurrences per respondent per year (4 process vents routed to control devices/refinery x 2 occurrences/process vent/year). |
| r. We assume 2 labor hours per occurrence, and that there will be 6 occurrences per respondent per year (3 heat exchange systems/refinery x 2 occurrences/heat exchange system/year). |
| s. We assume sources already have record systems in place to monitor existing operations. The burden shown below reflects reconstructed units affected by the standard. |
| t. We assume 12 occurrences per respondent per year and 24 labor hours per occurrence for recordkeeping requirements associated with heat exchange systems. The labor hours are divided equally between technical and plant operators. |
| u. We have included the labor associated with recording and transmitting data to develop initial and semiannual reports. We assume it takes respondents approximately 3.5 hours at each of the 9 storage vessels, 99 hours for equipment leaks at each of the 11 process units, 29 hours at each of the 4 process vents routed to control devices, and 1 hour at each of the 3 heat exchange systems. |
| v. We assume existing sources will provide initial training to employees associated with new affected facilities, and that there will be periodic refresher trainings. |
| w. We assume annual training for heat exchange system requirements will require 2 labor hours per operator, and assume there are 10 operators per facility. |
| x. Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
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| y. We assume that no new refineries will become subject to this regulation. New refineries will need to purchase and install LDAR equipment for heat exchange systems, including an FID analyzer and a portable air stripping column apparatus, for sample collection. For each refinery, we estimate the total cost to be $116,870, assuming a capital discount rate of 7 percent, annual interest over 10 years, and that there will be no other capital costs associated with other affected units. |
| z. The O&M cost assumes one mid-point calibration of sampling equipment prior to each sampling event. For each refinery, we assume 0.25 technical labor hours per sampling event, 12 sampling events per refinery per year, and 3 heat exchange systems per refinery. |
| N/A – Not Applicable |
| Table 2. Average Annual EPA Burden and Cost -NESHAP for Petroleum Refineries (40 CFR Part 63, Subpart CC) (Renewal) |
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|
|
46.67 |
62.9 |
25.25 |
|
| Activity |
(A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
(H) |
| EPA person-hours per occurrence |
No. of occurrences per plant per year |
EPA person-hours per plant per year
(C=AxB) |
Plants per year a |
Technical person-hours per year
(E=CxD) |
Management person-hours per year
(Ex0.05) |
Clerical person-hours per year
(Ex0.1) |
Cost b $ |
| 1. Initial notifications c |
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| Notification of reconstruction – process vents d |
1 |
0.4 |
0.4 |
142 |
56.8 |
2.84 |
5.68 |
$2,972.91 |
| Notification of compliance status – storage vessels e |
1 |
0.9 |
0.9 |
142 |
127.8 |
6.39 |
12.78 |
$6,689.05 |
| Notification of compliance status – equipment leaks e |
1 |
1.1 |
1.1 |
142 |
156.2 |
7.81 |
15.62 |
$8,175.51 |
| Notification of compliance status – process vents e |
1 |
0.9 |
0.9 |
142 |
127.8 |
6.39 |
12.78 |
$6,689.05 |
| Notification of compliance status – heat exchange systems |
2 |
0.3 |
0.6 |
142 |
85.2 |
4.26 |
8.52 |
$4,459.37 |
| Notification of performance test – process vent control devices e |
1 |
0.4 |
0.4 |
142 |
56.8 |
2.84 |
5.68 |
$2,972.91 |
| Notification of storage vessel inspections |
1 |
0.9 |
0.9 |
142 |
127.8 |
6.39 |
12.78 |
$6,689.05 |
| 2. Periodic reports f |
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| Review of startup, shutdown, malfunction reports |
N/A |
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|
|
| Semiannual parameter exceedance reports |
4 |
2 |
8 |
142 |
1136 |
56.8 |
113.6 |
$59,458.24 |
| Annual tank inspection failure reports |
4 |
1 |
4 |
142 |
568 |
28.4 |
56.8 |
$29,729.12 |
| Semiannual compliance – LDAR reports |
10 |
2 |
20 |
142 |
2840 |
142 |
284 |
$148,645.60 |
| Semiannual compliance – heat exchange system reports |
1 |
2 |
2 |
142 |
284 |
14.2 |
28.4 |
$14,864.56 |
| TOTAL LABOR BURDEN AND COST (Rounded) g |
6,400 |
$291,000 |
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| Assumptions: |
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| a. We estimate there are 142 existing petroleum refineries, and that no new refineries will become subject to the rule over the 3-year period of this ICR. We have further assumed that a refinery has the following affected units: 9 storage vessels; 11 process units subject to LDAR provisions; 9 process vents for requiring monitoring, recordkeeping, and reporting; and 3 heat exchange systems subject to a monthly sampling program for VOC leak detection and repair, as well as recordkeeping and reporting requirements to ensure compliance with the program. |
| b. Costs are based on the following labor rates: managerial rate of $62.90 (GS-13, Step 5, $39.31 + 60%), technical rate of $46.67 (GS-12, Step 1, $29.17 + 60%), and clerical rate of $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. |
| c. We assume that all existing respondents have complied with initial monitoring, recordkeeping and reporting requirements for existing units, including: initial notifications; the design analysis and establishment of operating parameters for storage vessels, LDAR initial requirements, initial performance testing for process vents routed to a control device; heat exchanger requirements, and development of startup and malfunction plans and record systems for each unit. Respondents having reconstructed units, however, must comply with initial requirements. We estimate that existing refineries will reconstruct 10 percent of their existing units (i.e., 0.9 storage vessels, 1.1 process units, 0.9 process vents, and 0.3 heat exchange systems per refinery). |
| d. The notification of reconstruction is only required for process vents routed to control devices. We assume that 4 process vents per refinery are routed to control devices, and of which existing refineries will reconstruct 10 percent. |
| e. The notification of compliance status includes performance test results, as required by the general provisions. |
| f. The rule requires that respondents submit semiannual compliance reports addressing each affected unit subject to the rule. |
| g. Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
| N/A – Not Applicable |