| 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) |
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| 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 |
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| 1. Applications |
N/A |
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Labor Rates: |
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| 2. Survey and Studies |
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Management |
147.40 |
These rates were updated 2/4/19 to match the United States Department of Labor, Bureau of Labor Statistics, June 2018, “Table 2. Civilian Workers, by occupational and industry group |
| A. Flare Management Plan |
160 |
1 |
160 |
0 |
0 |
0 |
0 |
$0 |
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Technical |
117.92 |
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Comment:
Added a line for facilities to revise existing flare management plans where a new flare is added. If EPA thinks these would be covered by existing plan, then can be removed.
B. Flare Management Plan Revisionb |
8 |
1 |
8 |
32 |
256 |
13 |
26 |
$33,534 |
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Clerical |
57.02 |
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| C. Root Cause Analysis (flow) |
45 |
4 |
180 |
150 |
27,000 |
1,350 |
2,700 |
$3,536,784.00 |
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| D. Root Cause Analysis (sulfur) |
24 |
3 |
72 |
150 |
10,800 |
540 |
1,080 |
$1,414,713.60 |
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| 3. Reporting Requirements |
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| A. Familiarize with rule requirements |
1 |
1 |
1 |
150 |
150 |
7.5 |
15 |
$19,648.8 |
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| B. Required Activities |
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| Initial performance tests on new facilities d |
40 |
1 |
40 |
100 |
4,000 |
200 |
400 |
$523,968.00 |
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| Repeat of initial performance tests on new facilities e |
40 |
0.05 |
2 |
100 |
200 |
10 |
20 |
$26,198.40 |
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| Initial CEMS Audits (RAA or CGA) new facilities f |
36 |
1 |
36 |
100 |
3,600 |
180 |
360 |
$471,571.20 |
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| CEMS Audits (RAA or CGA) existing facilities g |
36 |
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Comment:
=# CEMS (280 + 600) total /(150 facilities) times # of audits per year (1)
5.9 |
211 |
150 |
31,680 |
1,584 |
3,168 |
$4,149,826.56 |
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| Initial Relative Accuracy Test new facilities f |
24 |
6 |
144 |
100 |
14,400 |
720 |
1,440 |
$1,886,284.80 |
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| Relative Accuracy Test existing facilities g |
24 |
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Comment:
(280+450)/150 facilities x 2 test/yr
27.5 |
659 |
150 |
98,880 |
4,944 |
9,888 |
$12,952,488.96 |
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| Initial CPMS Audits (RAA or CGA) new facilities f |
36 |
4 |
144 |
100 |
14,400 |
720 |
1,440 |
$1,886,284.80 |
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| CPMS Audits (RAA or CGA) existing facilities g |
36 |
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Comment:
=number of CPMS (1180 total)/(150 facilities) x # audits/yr (2)
15.7 |
566 |
150 |
84,960 |
4,248 |
8,496 |
$11,129,080.32 |
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| C. Create Information |
See 3B |
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| D. Gather Existing Information |
See 3E |
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| E. Write Reporth |
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| Notification of construction, reconstruction, or modification |
2 |
1 |
2 |
100 |
200 |
10 |
20 |
$26,198.40 |
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| Notification of anticipated startup |
2 |
1 |
2 |
100 |
200 |
10 |
20 |
$26,198.40 |
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| Notification of actual startup |
2 |
1 |
2 |
100 |
200 |
10 |
20 |
$26,198.40 |
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| Notification of initial performance test |
2 |
1 |
2 |
100 |
200 |
10 |
20 |
$26,198.40 |
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| Report of performance test |
See 3B |
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| Semiannual Emissions Reportsi |
16 |
2 |
32 |
150 |
4,800 |
240 |
480 |
$628,761.60 |
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| Subtotal for Reporting Requirements |
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340,315 |
$38,763,939 |
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| 4. Recordkeeping Requirements |
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| A. Familiarize with rule requirements |
See 3A |
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| B. Plan Activities |
See 3B |
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| C. Implement Activities |
See 3B |
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| D. Develop Record System |
N/A |
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| E. Time to Enter Information |
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| Records of operating parametersj |
0.25 |
350 |
87.5 |
150 |
13,125 |
656 |
1,313 |
$1,719,270.00 |
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| F. Train Personnel |
N/A |
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| G. Audits |
N/A |
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832 |
# responses |
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| Subtotal for Recordkeeping Requirements |
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15,094 |
$1,719,270 |
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427 |
hr/response |
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| Total Labor Burden and Cost (rounded) k |
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355,000 |
$40,500,000 |
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| Total Capital and O&M Cost (rounded) k |
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$102,000,000 |
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| Grand TOTAL (rounded) k |
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$143,000,000 |
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| Assumptions |
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| a Occurrences per respondent per year is calculated as the number of affected facilities (flares, FCCU, FCU, FGCD, sulfur plant) times the occurences per affected facility per respondent (refineries). For CEMS/CPMS Audits or RATA testing, this value refers to the number of monitors on an affected facility that requires audit or testing. |
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| b Assume that there are approximately 150 petroleum refineries (respondents) that are subject to the rule over a 3-year period with at least one affected source. There will be no additional new petroleum refineries that will become subject to the rule over the three-year period of this ICR, but we assume that two facilities at each of the 150 petroleum refineries will become subject to the provisions of Subpart Ja over the three-year period of this ICR (100 affected facilities per year) due to being constructed, reconstructed, or modified and that these facilities will have initial performance testing costs. We assume 32 of these newly affected facilities will be flares. |
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| c This ICR uses the following labor rates: $147.40 per hour for Executive, Administrative, and Managerial labor; $117.92 per hour for Technical labor, and $57.02 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2018, “Table 2. Civilian Workers, by Occupational and Industry group.” The rates are from column 1, “Total Compensation.” The rates have been increased by 110% to account for the benefit packages available to those employed by private industry. |
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| d We have assumed that it will take 40 hours for each respondent to perform initial performance tests. |
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| e We have assumed that 5 percent of sources would have to repeat performance test due to failure. |
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| f We assume that two facilities at each of the 150 petroleum refineries will become subject to the provisions of Subpart Ja over the three-year period of this ICR (100 affected facilities per year) due to being constructed, reconstructed, or modified and that these facilities will have initial performance testing costs. We assume one CEMS monitor and two CPMS monitors needed for each newly affected facility. We assume that each new CEMS and CPMS monitor is audited at startup and once again in the first year (2x/yr), and that Relative Accuracy Audits or Cylinder Gas Audits take 36 hours. We assume that one initial relative accuracy test is required for each new CEMS and CPMS monitor (3 per new affected facility), that the relative accuracy test or RATA are conducted twice a year (3 x 2/yr), and take 24 hours per monitor. |
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| g Subpart Ja requires regular relative accuracy evaluations of all monitors on existing affected facilities. We assume there are 5.9 CEMS at each refinery (280 flare CEMS + 600 other equipment CEMS)/150 refineries), that these CEMS are audited once per year, and that the Relative Accuracy Audits or Cylinder Gas Audits take 36 hours. We assume that relative accuracy tests are required for each CEMS and CPMS monitor (3 per existing affected facility), that there are 13.7 CEMS and CPMS per refinery (280 flare CEMS + 280 flare CPMS + 600 other equipment CEMS + 900 other equipment CPMS)/150 refineries, that the relative accuracy test or RATA are conducted twice a year, and take 24 hours per monitor. We assume there are 7.9 CPMS at each refinery (280 flare CPMS + 900 other equipment CPMS)/150 refineries), that these CPMS are audited twice per year, and that these Relative Accuracy Audits or Cylinder Gas Audits take 36 hours. |
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| h We have assumed that each respondent will take 2 hours to write report. |
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| i We have assumed that each respondent will take 8 hours twice per year to complete semiannual reports |
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| j Assume operation 350 days per year as specified in the NSPS review document. |
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| k Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
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| 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) |
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| 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 |
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| New Affected Facilities: |
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Labor Rates: |
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| Report Review |
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Management |
65.71 |
These rates were updated 2/4/19 to match the rates from the Office of Personnel Management (OPM), 2018 General Schedule. |
Notification of construction, reconstruction,
or modificationc |
2 |
1 |
2 |
100 |
200 |
10 |
20 |
$10,935 |
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Technical |
48.75 |
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| Notification of anticipated startupd |
0.5 |
1 |
0.5 |
100 |
50 |
2.5 |
5 |
$2,734 |
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Clerical |
26.38 |
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| Notification of actual startupd |
0.5 |
1 |
0.5 |
100 |
50 |
2.5 |
5 |
$2,734 |
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| Notification of performance testd |
0.5 |
1 |
0.5 |
100 |
50 |
2.5 |
5 |
$2,734 |
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| Flare management planse |
1 |
1 |
1 |
32 |
32 |
1.6 |
3.2 |
$1,750 |
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| Review performance test results |
8 |
1 |
8 |
100 |
800 |
40 |
80 |
$43,739 |
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| Emission Reports |
4.2 |
1 |
4.2 |
100 |
420 |
21 |
42 |
$22,963 |
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| Existing Plants: |
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| Semiannual Emissions Reportsf |
4.2 |
2 |
8.4 |
150 |
1260 |
63 |
126 |
$68,888.61 |
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| TOTAL (rounded) g |
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3,290 |
$156,000 |
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| Assumptions: |
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| a Assume that there are approximately 150 petroleum refineries (respondents) that are subject to the rule over a 3-year period. There will be no additional new petroleum refineries that will become subject to the rule over the three-year period of this ICR, but we assume that two facilities at each of the 150 petroleum refineries will become subject to the provisions of Subpart Ja over the three-year period of this ICR (100 affected facilities per year) due to being constructed, reconstructed, or modified and that these facilities will perform initial performance testing. |
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| b This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: Managerial rate of $65.71 (GS-13, Step 5, $41.07 + 60%), Technical rate of $48.75 (GS-12, Step 1, $30.47 + 60%), and Clerical rate of $26.38 (GS-6, Step 3, $16.49 + 60%). These rates are from the Office of Personnel Management (OPM) “2018 General Schedule” which excludes locality rates of pay. |
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| c We have assumed that all sources with newly affected facilities (due to being constructed, reconstructed, or modified) will take 2 hours to complete report. |
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| d We have assumed that all sources with newly affected facilities (due to being constructed, reconstructed, or modified) will take 0.5 hours to complete report. |
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| 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. |
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| f We have assumed that all existing plants will be required to complete semiannual emissions reports. |
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| g Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
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