1844ss10

SUPPORTING STATEMENT
ENVIRONMENTAL PROTECTION AGENCY
NESHAP FOR PETROLEUM REFINERIES, CATALYTIC CRACKING UNITS,
CATALYTIC REFORMING UNITS AND SULFUR RECOVERY UNITS
40 CFR PART 63, SUBPART UUU
JULY 2015
1. Identification of the Information Collection
1(a) Title of the Information collection
“National Emission Standards for Petroleum Refineries: Catalytic Cracking Units,
Catalytic Reforming Units, and Sulfur Recovery Units” (40 CFR part 63, subpart UUU). This is
a revision of an existing information collection request (ICR); the OMB Control Number is
2060-0554 and the EPA tracking number is 1844.07.
1(b) Short Characterization/Abstract
This ICR covers information collection requirements in the final amendments to the
Petroleum Refineries, Catalytic Cracking Units, Catalytic Reforming Units, and Sulfur Recovery
Units NESHAP (40 CFR part 63, subpart UUU).
The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Petroleum
Refineries, Catalytic Cracking Units, Catalytic Reforming Units, and Sulfur Recovery Units
(40 CFR part 63, subpart UUU) were proposed on September 11, 1998, promulgated on
April 11, 2002, and amended on February 9, 2005. These regulations apply to three types of
affected sources at major source petroleum refineries. The three affected sources are: the fluid
catalytic cracking unit catalyst regeneration; the catalytic reforming unit catalyst regeneration;
and the sulfur recovery unit. The rule also includes requirements for by-pass lines associated
with the three affected sources. New facilities include those that commenced construction or
reconstruction after the date of proposal.
The EPA is finalizing to amend subpart UUU to revise the operating standards for fluid
catalytic cracking units and clarify the requirements for catalytic reforming units and sulfur
recovery units. The potential respondents are owners or operators of any existing or new
petroleum refinery facilities. There are an estimated 142 major source refinery facilities subject
to the Petroleum Refineries Catalytic Cracking Units, Catalytic Reforming Units, and Sulfur
Units NESHAP. Emission points affected by the final amendments to subpart UUU are fluid
catalytic cracking unit catalyst regeneration, catalytic reforming catalyst regeneration, and sulfur
recovery units. Significant changes include new testing requirements and more stringent
operating limits for fluid catalytic cracking unit catalyst regeneration, revisions to requirements
for catalytic reforming catalyst regeneration when using active purging, and the addition of an
alternative emissions limit for sulfur recovery units using oxygen enriched air. Other significant
changes include new electronic reporting requirements for performance test reporting and
revised monitoring requirements. An overarching change to all NESHAP regulations is a change
in policy with regards to emission requirements and associated monitoring, recordkeeping, and
reporting during startup, shutdown, and malfunctions. These changes include new emission

2
limits for startup and shutdown for fluid catalytic cracking unit catalyst regeneration and sulfur
recovery units
This information is being collected to assure compliance with 40 CFR part 63, subpart
UUU. This ICR estimates burden for 142 major source refineries to comply with the amended
provisions for fluid catalytic cracking units and sulfur recovery units. 1 The reduction in burden
as a result of electronic reporting is included in this ICR. The burden associated with startups,
shutdowns, and malfunctions did not change.
2. Need for and Use of the Collection
2(a) Need/Authority for the Collection
The EPA is charged under section 112 of the Clean Air Act, as amended, to establish
standards of performance for each category or subcategory of major sources and area sources of
hazardous air pollutants. These standards are applicable to new or existing sources of hazardous
air pollutants and shall require the maximum degree of emission reduction. Section 112 also
requires that the Administrator review and, if appropriate, revise such standards every 8 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.
Certain records and reports are necessary for the Administrator to confirm the compliance
status of sources subject to NESHAP, identify any new or reconstructed sources subject to the
standards, and confirm that the standards are being achieved on a continuous basis. These
recordkeeping and reporting requirements are specifically authorized by section 114 of the Clean
Air Act (42 U.S.C. 7414) and set out in the part 63 NESHAP General Provisions. The
recordkeeping and reporting requirements for title V permits are contained in 40 CFR 70.6 and
40 CFR 71.6. Under parts 63 and 70 or 71, the owner or operator must keep each record for
5 years following the date of each occurrence, measurement, maintenance, corrective action,
report, or record.
1
The previous ICR for this subpart (EPA ICR Number 1844.04, OMB Control Number 2060-0554) included
estimates of the monitoring, recordkeeping, and reporting burden for less than 1 refinery. No new or reconstructed
facilities were expected over those 3 years. However, it was estimated that three affected emission source units had
qualified for a compliance date extension and would be complying with the initial compliance requirements during
the period of that ICR (one per year); and one affected facility (0.33 per year) would conduct a performance test due
to a process/operating change.

3
2(b) Practical Utility/Users of the Data
The information will be used by the delegated authority (State agency, or Regional
Administrator if there is no delegated State agency) to ensure that the standards and other
requirements are being achieved. Based on review of the recorded information at the site and the
reported information, the delegated permitting authority can identify facilities that may not be in
compliance and decide which facilities, records, or processes may need inspection.
3. Non-duplication, Consultations, and Other Collection Criteria
The requested recordkeeping and reporting are required under 40 CFR part 63, subpart
UUU.
3(a) Non-duplication
For notifications and reporting not required to be submitted electronically, 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
This section is not applicable because this is a rule-related ICR.
3(c) Consultations
The final amendments are based upon the data provided by each individual refinery in
response to an EPA survey of the petroleum refinery industry in 2011 (data from calendar year
2010) which were compiled into a Petroleum Refinery Database. The final amendments were
also developed in consultation with trade associations, including Matt Todd of the American
Petroleum Institute (API) and David Freidman of the American Fuel and Petrochemical
Manufacturers (AFPM). The assumptions made in the development of this ICR, including the
estimate of the number of petroleum refineries subject to the standard, were updated by
reviewing the EPA’s Petroleum Refinery Database, as well as the Agency’s internal data
sources, such as our own industry experts and the Air Facility System (AFS), which is the EPA
database for the collection, maintenance, and retrieval of all compliance data. The information in
AFS is reported by industry as required in the recordkeeping and reporting provisions of the
standard. AFS is operated and maintained by the EPA Office of Compliance. We have estimated
that there are approximately 142 existing respondents subject to the standard, and no new
sources will become subject to the standard over the 3-year period covered by this ICR.
The EPA also provided a 60-day public comment period after proposal of the
amendments to subpart UUU. All affected parties were given the opportunity to comment on the
proposed amendments during this period. The EPA considered all of the comments received and
incorporated them, as appropriate, in developing the final amendments.

4
3(d) Effects of Less Frequent Collection
If the relevant information were collected less frequently, the delegated permitting
authority (State or EPA) will not be reasonably assured that a facility is in compliance with the
standards.
3(e) General Guidelines
None of the guidelines in 5 CFR 1320.5 are being exceeded.
3(f) Confidentiality
All 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 (CBI) (see 40 CFR 2; 41 FR 36902, September 1,
1976; amended by 43 FR 39999, September 8, 1978; 43 FR 42251, September 28, 1978; 44 FR
17674, March 23, 1979).
3(g) Sensitive Questions
This section is not applicable because this ICR does not involve matters of a sensitive
nature.
4. The Respondents and the Information Requested
4(a) Respondents/NAICS Codes
The potential respondents to the recordkeeping and reporting requirements under subpart
UUU are owners or operators of existing or new major source petroleum refineries. The North
American Industry Classification System (NAICS) code is 32411 for petroleum refineries that
operate catalytic cracking units, catalytic reforming units, or sulfur recovery units.
4(b) Information Requested
(i) Data Items
In this ICR, all the data that is recorded or reported is required by the final amendments
to NESHAP for Petroleum Refineries, Catalytic Cracking Units, Catalytic Reforming Units, and
Sulfur Recovery Units (40 CFR part 63, subpart UUU).
A source must make the following reports:
Notification Reports
Notification of performance tests

63.7(a) and 63.9(e),
63.1574(a)(3)

Operation, maintenance, and monitoring plan

63.1574(f)

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Reports
Semiannual compliance reports

63.10(e)(3),
63.1575(c), (g)

Performance test reports– electronic reporting

63.1571(a)(5) and (6),
63.1575(f), (k)

A source must keep the following records:
Recordkeeping
Maintain malfunction records
Operation, maintenance, and monitoring plan

63.1576(a)(2)
63.1576(e)

Emissions data

63.1576(a)(3),
63.1576(d), 63.10(d)

Monitoring data

63.1576(d)

Electronic Reporting. We are finalizing electronic reporting of performance test reports
and CEMS performance evaluation data. Electronic reporting is common in environmental data
collection, provides standardization of data reporting formats, and reduces reporting burden for
the regulated community.
(ii) Respondent Activities
The respondent activities that will be required by the final amendments to subpart UUU
include the following activities:
Respondent Activities
Read instructions.
Install, calibrate, maintain, and operate CMS or emission monitoring for catalytic cracking
units, catalytic reforming units, and sulfur recovery systems.
Perform performance test for fluid catalytic cracking unit catalyst regeneration every 5 years
or more frequently, Reference Method 5, 5B or 5F (of appendix A to 40 CFR Part 60) test for
PM, and repeat performance tests if necessary.
Perform performance test for catalytic cracking unit catalyst regeneration one time, Reference
Method 320 (of appendix A to 40 CFR Part 63) test for HCN.
Write the performance test notifications.
Revise the operating, maintenance, and monitoring plan.
Submit the required reports developing, acquiring, installing, and utilizing technology and
systems for the purpose of collecting, validating, and verifying information.

6
5. The Information Collected: Agency Activities, Collection Methodology, and Information
Management
5(a) Agency Activities
The 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 every 5 years or more
frequently for catalytic cracking unit catalyst regeneration, required to be submitted by
industry.
Audit facility records.
Input, analyze, and maintain data in the Air Facility System (AFS).

5(b) Collection Methodology and Management
Performance test reports are used by the Agency to discern a source’s capability to
comply with the emission standard. Data and records maintained by the respondents are
tabulated and published for use in compliance and enforcement programs. The semiannual
compliance reports are used for problem identification, as a check on source operation and
maintenance, and for compliance determinations.
Some of the information contained in the reports is entered into AFS, which is operated
and maintained by the EPA’s Office of Compliance and Enforcement. AFS is the EPA’s
database for the collection, maintenance, and retrieval of compliance and annual emission
inventory data for over 100,000 industrial and government-owned facilities. The data entered
into AFS is focused on compliance inspections, enforcement actions, and issuance of permits.
The EPA uses the AFS for tracking air pollution compliance and enforcement by local and state
regulatory agencies, EPA regional offices and EPA headquarters. The EPA and its delegated
authorities can edit, store, retrieve and analyze the data.
As part of the final revisions to this rule, all data that are required to be reported
electronically will be collected through the EPA’s Compliance and Emissions Data Reporting
Interface (CEDRI), which is part of the EPA’s Central Data Exchange. The data collected via
CEDRI will be more extensive than the data collected through AFS and will be visible to the
public through WebFIRE.
The records required by this regulation must be retained by the owner or operator for
5 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

7
development of the regulation. A small entity for petroleum refineries is defined as a firm having
no more than 1,500 employees. The final amendments would not result in any adverse impacts
on a substantial number of small entities in the Petroleum Refining Source Category. The final
amendments would not create any new requirements or burdens for existing sources other than
minimal notification requirements, and for some facilities, performance testing requirements.
5(d) Collection Schedule
The specific frequency for each information collection activity within this request is
shown below in Table 1: Annual Respondent Burden and Cost: Final Amendments to NESHAP
for Petroleum Refineries, Catalytic Cracking Units, Catalytic Reforming Units, and Sulfur
Recovery Units (40 CFR Part 63, Subpart UUU).
6. Estimating the Burden and Cost of the Collection
Table 1 documents the computation of individual burdens for the final recordkeeping and
reporting requirements applicable to the industry for each of the subparts 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 3 years from these recordkeeping
and reporting requirements is estimated to be 4,940 (Total Labor Hours from Table 1). The
recordkeeping hours shown below in Table 1 are 23. The reporting requirement hours shown
below in Table 1 are 4,914. These hours are based on Agency studies and background documents
from the development of the regulation and Agency knowledge and experience with the
NESHAP program. The average annual burden over the next 3 years was estimated assuming
one-third of all facilities would comply each year.
6(b) Estimating Respondent Costs
(i) Estimating Labor Costs
This ICR uses the following labor rates:
Managerial
Technical
Clerical

$130.26
$84.95
$41.18

($62.03 + 110%)
($40.45 + 110%)
($19.61 + 110%)

Labor rates and associated costs are based on the Bureau of Labor Statistics (BLS) data.
Technical, management, and clerical average hourly rates for private industry workers were
taken from the Occupational Employment Statistics: NAICS 324 (Petroleum and Coal Products
Manufacturing), May 2009 Employment and Wage Estimates. These BLS rates represent salaries

8
plus fringe benefits and do not include the cost of overhead. The rates have been increased by
110 percent to account for the benefit packages available to those employed by private industry.
(ii) Estimating Capital and Operation and Maintenance Costs
The type of industry costs associated with the information collection activities in the
subject standards are both labor costs which are addressed elsewhere in this ICR and the costs
associated with continuous monitoring.
The capital costs are one-time costs for a facility subject to the regulation. There are no
capital costs associated with the information collection requirements of the final amendments to
subpart UUU.
An annual operation and maintenance cost for this subpart includes performance testing.
The final amendments do require an estimated 101 facilities to conduct periodic performance
testing for particulate matter every 5 years for catalytic cracking unit catalyst regeneration,
unless the particulate matter emissions measured during the most recent performance test are in
excess of 0.8 g/kg coke burn-off when using the fixed 20 percent opacity operating limit
compliance alternative, in which case the testing frequency will be annually. Additionally, a onetime performance test for HCN is required for catalytic cracking unit catalyst regeneration as part
of the final amendments. There are 116 catalytic cracking units. In the 3 years following
promulgation, the estimated cost for particulate matter performance testing is an average of
$391,307 per year ($9,200 per unit for EPA Method 5 performance test × 116 units × 1.1 / 3
years = $391,307/yr). 2 In the 3 years following promulgation, the estimated cost for the one-time
HCN test is an average of $386,667 per year ($10,000 per FCCU for EPA Method 320
performance test x 116 FCCUs / 3 years = $386,667/yr).
There are also labor costs associated with performing a one-time engineering evaluation
and personnel training relative to the catalytic reforming unit operational requirements in the
final rule. The rule requirements are subject only to units using active purge, and we expect this
to be approximately 10-percent of the 151 total units at all refineries (i.e., 15 units).
(iii) Annualizing Capital Costs
There are no annualized capital costs associated with the information collection
requirements of the final amendments.
6(c) Estimating Agency Burden and Cost
The only costs to the Agency are those costs associated with analysis of the reported
information. The EPA compliance and enforcement program includes activities such as: the

2

The final rule requires FCCU to conduct EPA Reference Method (M5) PM testing every 5 years, unless the
“NSPS J” compliance option is used and the PM emissions rate during the most recent test is greater than 0.8 g
PM/kg coke burn-off. For facilities in excess of that rate, testing will be required annually. It was assumed that
approximately 10% of sources will require annual testing. Therefore, the number of units was multiplied by 1.1 to
account for annual testing of some units.

9
review 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 3 years of the ICR is estimated to be $11,728
(see Table 2 below.)
This cost is based on the average hourly labor rate as follows:
Managerial
Technical
Clerical

$61.36
$45.52
$24.64

(GS-13, Step 5, $38.35 + 60%)
(GS-12, Step 1, $28.45 + 60%)
(GS-6, Step 3, $15.40 + 60%)

These rates are from the Office of Personnel Management (OPM) 2009 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.
6(d) Estimating the Respondent Universe and Total Burden and Costs
There are currently 142 major source refineries in the United States and no new refineries
are expected to be built during the next 3-year period. It is estimated that no additional
respondents per year will become subject to the standard. The overall average number of
respondents per year subject to this standard is calculated using the following table that addresses
the 3 years covered by this ICR.
Number of Respondents
Respondents That Submit
Reports
Year

(A)
Number of New
Respondents a

(B)
Number of
Existing
Respondents

Respondents That Do
Not Submit Any
Reports
(C)
Number of Existing
Respondents that keep
records but do not
submit reports

(D)
(E)
Number of
Number of
Existing
Respondents
Respondents That
(E=A+B+C-D)
Are Also New
Respondents
1
0
47.3
0
0
47.3
2
0
94.7
0
0
94.7
3
0
142
0
0
142
Average
0
94.7
0
0
94.7
a
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 3-year period of this ICR is 94.7.

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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

(E)
Total Annual
Responses
E=(B×C)+D

1.15 c

(D)
Number of Existing
Respondents That
Keep Records But Do
Not Submit Reports
0

Notification of particulate
matter performance test
Notification of HCN
performance test
Operation, maintenance, and
monitoring plan
Particulate matter performance
test reports
HCN performance test reports
Engineering evaluation and
training for catalytic reforming
unit operational requirements

37.0 a
33.7 b

1.15 c

0

38.8

33.7 d

1

0

33.7

37.0 a

1.15 c

0

42.6

33.7 b
5.0e

1.15 c
1

0
0

38.8
5.0

42.6

Total
201.5
There are 101 facilities with catalytic cracking units conducting a performance test once every 5 years. In the 3
years following promulgation, 101 facilities will test their catalytic cracking unit catalyst regeneration. Additionally,
it was assumed 10 percent of the respondents would be required to test annually for a total of 37.1 respondents
annually i.e., 101 × 1.1 / 3 years = 37.0 facilities/year that respond.
b
There are 101 facilities with catalytic cracking units conducting a one-time performance test. In the 3 years
following promulgation, 101 facilities will test their catalytic cracking unit catalyst regeneration, so there are 33.7
respondents per year, i.e., 101 facilities / 3 years = 33.7 facilities/year that respond.
c
There are approximately 116 catalytic cracking units at 101 facilities, so each facility would report 1.15 responses
per year, i.e., 116 units / 101 facilities = 1.15 responses/facility.
d
Assumed 101 facilities must revise the operation, maintenance, and monitoring (OMM) Plan due to monitoring
requirement changes for catalytic cracking unit catalyst; we assumed that one-third of facilities comply in each of
the 3 years following promulgation, so that 33.7 facilities will revise the plan each year.
d
The rule requirements are subject only to units using active purge, and we expect this to be approximately 10
percent of the 151 total units at all refineries (i.e., 15.1 units / 3 years = 5.0 respondents/year).
a

The number of Total Annual Responses is 202 (rounded) (81.2 annual responses for the
notification of performance test, 33.7 annual responses for the operation, maintenance, and
monitoring plan, 81.2 annual responses for the performance test reports) and 5.0 for catalytic
reforming unit engineering evaluation and training. The total annual labor costs are $410,000
(rounded). Details regarding these estimates may be found below in Table 1: Annual Respondent
Burden and Cost: Final Amendments to NESHAP for Petroleum Refineries, Catalytic Cracking
Units, Catalytic Reforming Units, and Sulfur Recovery Units (40 CFR Part 63, Subpart UUU) .
6(e) Bottom Line Burden Hours 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.

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(i) Respondent Tally
The bottom line respondent burden hours and costs, presented in Table 1, are calculated
by adding person-hours per year down each column for technical, managerial, and clerical staff,
and by adding down the cost column. The average annual burden for the recordkeeping and
reporting requirements in the final amendments to subpart UUU for the 142 major source
facilities that are subject is 4,940 person-hours, with an annual average cost of $410,328. Details
regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost:
Final Amendments to NESHAP for Petroleum Refineries, Catalytic Cracking, Reforming and
Sulfur Units (40 CFR Part 63, Subpart UUU).
There are no annual capital costs associated with the final amendments; the operation and
maintenance costs associated with the final amendments include performance testing costs for
the regulated entity of $777,973 per year. The cost calculations are detailed in Section 6(b)(ii),
Capital vs. Operation and Maintenance (O&M) Costs.
(ii) The Agency Tally
The average annual Agency burden and cost over next 3 years is estimated to be 264
labor hours (rounded) at a cost of $11,700 (rounded). See below Table 2: Annual Agency Burden
and Cost: Final Amendments to NESHAP for Petroleum Refineries, Catalytic Cracking Units,
Catalytic Reforming Units, and Sulfur Recovery Units (40 CFR Part 63, Subpart UUU) .
6(f) Reasons for Change in Burden
The change in burden estimate reflects the additional requirements of the final
amendments to 40 CFR part 63, subpart UUU.
6(g) Burden Statement
The average annual respondent burden for the final amendments for subpart UUU is
estimated at 4,940 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 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, the EPA has established a public docket for this ICR
under Docket ID Number EPA-HQ-OAR-2010-0682, which is available for on-line viewing at

12
www.regulations.gov, or in person viewing at the Air and Radiation Docket and Information
Center in the EPA Docket Center (EPA/DC), EPA West, Room B102, 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 (202) 566-1744, and the telephone number for the Air and Radiation
Docket and Information Center is (202) 566-1742. 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, you can send comments 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-OAR-2010-0682 in any correspondence.
Part B of the Supporting Statement
This part is not applicable because no statistical methods were used in collecting this
information.

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Table 1. Annual Respondent Burden and Cost: Final Amendments to NESHAP for Petroleum Refineries, Catalytic Cracking
Units, Catalytic Reforming Units, and Sulfur Recovery Units (40 CFR Part 63, Subpart UUU)
(A)
Burden item

1. Applications
2. Survey and Studies
3. Acquisition, Installation, and
Utilization of Technology and Systems
4. Reporting Requirements
A. Read instructions c
B. Required activities
Initial Performance test d
PM Performance test (internal) e
HCN Performance test (internal)f
Operating, maintenance, and
monitoring plan g
C. Create information
D. Gather existing information
E. Write report
Notification of
construction/reconstruction d
Notification of actual startup d
Notification of special compliance
requirements
Notification of PM performance test e
Notification of HCN performance
testf
Notification of compliance Status d
Extended compliance request
Report of performance test

Personhours per
occurrence

(B)
No. of
occurrences
per respondent
per year

(C)
Personhours per
respondent
per year
(C=A×B)

N/A
N/A
40

1

40

2

1

40
40
40
20

(D)

(E)
Technical
personhours per
year
(E=C×D)

Management
person-hours
per year
(E×0.05)

(G)
Clerical
personhours per
year
(E×0.1)

0

0

0

0

2

94.7

189.3

9.5

18.9

$18,096

1
1
1
1

40
40
40
20

0
42.5
38.7
33.7

0
1701.3
1546.7
673.3

0
85.1
77.3
33.7

0
170.1
154.7
67.3

$0
$162,607
$147,825
$64,355

2

1

2

0

0

0

0

$0

2
N/A

1

2

0

0

0

0

$0

2
2

1
1

2
2

42.5
38.7

85.1
77.3

4.3
3.9

8.5
7.7

4
N/A
See 4B

1

4

0

0

0

0

Respondents
per year a

(F)

(H)

Cost,$ b

$0

See 4B
See 4B

$8,130
$7,391
$0

14
(A)
Burden item

Semiannual compliance reports h
Annual report
5. Recordkeeping Requirements
A. Read instructions
B. Plan activities
C. Implement activities
D. Develop record system d
E. Time to enter information
Records of operations i
F. Time to train personnel j
G. Time to adjust existing ways to
comply with previously applicable
requirements d
H. Time to transmit or disclose
Information k
I. Time for audits
Subtotal Labor Burden
TOTAL ANNUAL NUMBER OF
RESPONSES
ANNUAL CAPITAL COSTS
PM Performance Tests (outsourced) l
HCN Performance Tests (outsourced) m
OPERATION AND MAINTENANCE
COSTS
TOTAL LABOR BURDEN AND
COST

Personhours per
occurrence

(B)
No. of
occurrences
per respondent
per year

10.0
0

2
0

(C)
Personhours per
respondent
per year
(C=A×B)
20.0
0.0

(D)

0
0

(E)
Technical
personhours per
year
(E=C×D)
0
0

Management
person-hours
per year
(E×0.05)
0
0

(G)
Clerical
personhours per
year
(E×0.1)
0
0

1
4
N/A

52
1

52
4

0
5.0

0
20

0
1.0

0
2.0

$0
$1,924

0.25

2

0.5

0

0

0.0

0.0

$0

4,293

215
4,940

429

Respondents
per year a

(F)

(H)

Cost,$ b
$0
$0

See 4A
See 4B
See 4B
N/A

N/A
$410,328
201
NA
$391,307
$386,667
NA
$1,188,301

15
Assumptions:
a
We have determined that there are 142 major petroleum refineries that have one or more affected facilities subject to the standard. No new or reconstructed
facilities are expected over the next 3 years. We assumed that approximately one-third of facilities would comply with the amended rule in each of the 3 years
following promulgation, so that 47.3 facilities would comply and be subject the first year, 94.7 facilities would be subject the second year, and 142 facilities
would be subject the third year. We assumed costs based on the second year, with 94.7 facilities subject to the rule.
b
This ICR uses the following labor rates: $130.26 per hour for Executive, Administrative, and Managerial labor; $84.95 per hour for Technical labor, and $41.18
per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, May 2009. 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
Assumed 142 facilities have to read the amended UUU rule. Assumed costs based on the second year, with 94.7 facilities subject to the rule.
d
Assumed that this activity has already occurred for existing sources.
e
The final rule requires catalytic cracking unit catalyst regeneration to conduct EPA Reference Method (M5) PM testing every 5 years, unless the unit is subject
to the “NSPS J” compliance option and the PM emissions rate during the most recent test is greater than 0.8 g PM/kg coke burn-off. For units in excess of that
rate, testing is required annually. It was assumed that 10 percent of sources will require annual testing. There are 116 FCCUs that will test over the 3 years after
promulgation, so each year, approximately 42.5 performance tests will be conducted (116 units × 1.1 / 3 years = 42.5 tests/year.
f
The final rule requires each catalytic cracking unit to conduct a one-time EPA Reference Method 320 test for HCN. There are 116 units that will test over the 3
years after promulgation, so each year, approximately 38.7 performance tests will be conducted (116 units / 3 years = 38.7 tests/year).
g
Assumed approximately 101 facilities must revise the OMM Plan due to monitoring requirement changes for catalytic cracking unit catalyst regeneration; we
assumed that one-third of facilities comply in each of the 3 years following promulgation, so that 33.7 facilities will revise the plan each year. Assumed 20 hr to
revise the OMM Plan.
h
Assumed all facilities submit semiannual compliance reports, however, this requirement is already in the rule and no changes to this requirement are made in
the current rule action.
i
Assumed it requires facilities 1 hour to record data per week (52 weeks), and all facilities would record; however this requirement is already in the rule and no
changes to this requirement are made in the current rule action.
j
These costs reflect the one-time engineering evaluation and personnel training costs relative to the catalytic reforming unit catalyst regeneration operational
changes made in the final rule. Assumed the training is needed for 10 percent of the catalytic reforming units. There are 151 catalytic reforming units and we
assumed one-third of the facilities conduct training for their units each year, so training takes place at 5.0 units per year (i.e., 151 × 0.1 / 3). Other costs
associated with the one-time annual training that all facilities would conduct which is already required by the rule and is being unchanged by the final
amendments is not included in this burden estimate.
k
Assumed it requires facilities 15 minutes to transmit information semiannually and that all facilities would submit each year; however, this requirement is
already in the rule and no changes to this requirement are made in the current rule action.
l
Assumed that an EPA Reference Method 5 performance test would cost approximately $9,200, and 42.5 performance tests would be conducted each year in the
3 years following promulgation. The final rule requires resting of PM from catalytic cracking unit catalyst regeneration using EPA Reference Method 5 once
every 5 years, unless unit is subject to the “NSPS J” compliance option and the PM emissions rate during the most recent test is greater than 0.8 g PM/kg coke
burn-off. For units in excess of that rate, testing is required annually. Assumed 10% of sources will require annual testing. There are 116 units that will test over
the 3 years after promulgation, so each year, approximately 42.5 tests will be conducted each year (116 ×1.1 / 3).
m
Assumed that an EPA Reference Method 320 performance test would cost approximately $10,000, and 38.7 performance tests would be conducted each year in
the 3 years following promulgation (116 units / 3 years = 38.7 units/year).

16
Table 2. Annual Burden and Cost to the Federal/State Government: Final Amendments to NESHAP for Petroleum Refineries,
Catalytic Cracking, Reforming and Sulfur Units (40 CFR Part 63, Subpart UUU)

Activity

Report Review
Notification of construction/reconstruction
Notification of actual startup
Notification of special compliance
requirements
Notification of initial performance test b
Notification of PM performance test c
Notification of HCN performance test d
Notification of compliance status
Review of operation, maintenance, and
monitoring plan e
Review of repeat performance test report
Review of compliance report
Review of semiannual compliance reports f
Review of NESHAP waiver application
Subtotal Labor Burden
TOTAL LABOR BURDEN AND COST

(A)

(B)

(C)

(D)
Technical
person-hours
per year
(E=B×C)

(E)
Management
person-hours
per year
(D×0.05)

(F)
Clerical
person- hours
per year
(D×0.1)

Hours per
occurrence

Hours per
plant per year

Plants per
year

2
2
2
2

(G)

42.5
38.7
0
33.7

85.1
77.3
0.0
67.3

4.3
3.9
0.0
3.4

8.5
7.7
0.0
6.7

$4,343
$3,948
$0
$3,438

8

0

0.0

0.0

0.0

$0

4
4

0
0

0.0
0.0
230

0.0
0.0
11
264

0.0
0.0
23

$0
$0
$11,728
$11,728

Cost,$ a

N/A
N/A
N/A
NA
2
2
2
2
8
N/A
2
4

Assumptions:
a
This ICR uses the following labor rates: Managerial rate of $61.36 per hour (GS-13, Step 5, $38.35 + 60%); Technical rate of $45.52 per hour (GS-12, Step 1,
$28.45 + 60%); and Clerical rate of $24.64 per hour (GS-6, Step 3, $15.40 + 60%). These rates are from the Office of Personnel Management (OPM) 2009
General Schedule, which excludes locality rates of pay.
b
Assumed that this activity has already occurred for existing sources.
c
The final rule requires PM testing of catalytic cracking unit catalyst regeneration using EPA Reference Method 5 once every 5 years, unless the unit is subject
to the “NSPS J” compliance option and the PM emissions rate during the most recent test is greater than 0.8 g PM/kg coke burn-off. For facilities in excess of
that rate, testing is required annually. Assumed 10 percent of sources will require annual testing. There are 116 units that will test over the 3 years after
promulgation, so each year, approximately 42.5 tests will be conducted each year (116 ×1.1 / 3).
d
The final rule requires a one-time HCN performance test for each catalytic cracking unit using EPA Reference Method 320. There are 116 units that will test
over the 3 years after promulgation, so each year, approximately 38.7 performance tests will be conducted (116 units / 3 years = 38.7 tests/year).

17
e

Assumed approximately 101 facilities must revise the OMM Plan due to monitoring requirement changes for FCCUs (there are 116 FCCUs at 101 facilities in
the source category); we assumed that one-third of facilities comply in each of the 3 years following promulgation, so that 33.7 facilities will revise the plan each
year. Assumed 2 hours for review of the OMM Plan.
f
We have determined that there are 142 major petroleum refineries that have one or more affected facilities subject to the standard. No new or reconstructed
facilities are expected over the next 3 years. For the current burden estimate, however, we note that this requirement is already in the rule and no changes to this
requirement are made in the current rule action.