The affected entities are subject to
the General Provisions of the NESHAP at 40 CFR part 63, subpart A,
and any changes, or additions to the Provisions specified at 40 CFR
part 63, subpart UUU. Owners or operators of the affected
facilities must submit initial notification, performance tests, and
periodic reports, and results. Owners or operators 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. Reports, at a minimum, are required
semiannually.
There is an increase in the
total estimated burden as currently identified in the OMB Inventory
of Approved Burdens. The increase in burden from the most- recently
approved ICR is primarily due to the December 2015 final rule
amendments. The changes to 40 CFR Part 63 Subpart UUU caused by the
rule amendment are summarized in section 1(b). The specific changes
that impacted this ICR are (1) the elimination of the SSM
exemption, (2) the requirement for FCCUs to do periodic PM
performance testing and a one-time HCN performance test, and (3)
revisions to requirements for catalytic reforming catalyst
regeneration when using active purging. This ICR accounts for the
burden presented previously in both EPA ICR Number 1844.06
(existing rule) and EPA ICR Number 1877.07 (2015 amendment). The
elimination of the SSM exemption did not lead to any changes to the
time or cost burden estimates, or to the number of responses,
because the previous assumption was that all existing respondents
have already complied with the initial requirements to prepare and
submit the SSM plan, thus the time and cost estimate was already
zero. In this supporting statement, we have added a footnote in
Table 1 to explain that the SSM exemption has been eliminated and
that the burden item can be removed out of future ICR supporting
statements. We have accounted for the additional labor and O&M
costs to notify, perform, and prepare and submit the reports for
the PM and HCN performance tests for FCCUs. We have also accounted
for the additional labor for owners or operators of facilities with
FCCUs to update their operating, maintenance, and monitoring plan,
to account for the new requirements. We have also accounted for the
additional labor and responses associated with training personnel
and performing an engineering assessment for evaluation of the new
catalytic reforming unit operational requirements. Furthermore, we
have added a new burden item for performing relative accuracy test
audits on units using CEMs, based on industry comments received
from API (further discussed in Section 3(c)). This contributed to
an increase in the total labor burden, cost and number of annual
responses. In addition, the total number of respondents was revised
from 123 to 142, which contributed to the increase in burden and
cost.
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.
1844ss08.docx
Recordkeeping and Reporting Requirements for Petroleum Refinery NESHAP