Burden Tables

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Overview

Table 1
Table 2
O&M
Responses

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Sheet 1: Table 1

Table 1: Annual Respondent Burden and Cost – NESHAP for Petroleum Refineries: Catalytic Cracking Units, Catalytic Reforming Units, and Sulfur Recovery Units (40 CFR Part 63, Subpart UUU) (Renewal)
					120.27	141.06	58.67
Burden item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	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)	Management person-hours per year (Ex0.05)	Clerical person- hours per year (Ex0.1)	Total Cost per Year $b		Type of affected unit	Number of respondents	Number of Units	Number of Respondents using CEMs	Number of units using CEMs
1. Applications	N/A									FCCU	101	116	-	-
2. Survey and Studies	N/A									CRU	114	151	-	-
3. Reporting Requirements										SRU	DWang: These numbers are from 1844.06 105	253	27	65
A. Familiarize with rule requirements c	2	1	2	142	284	14.20	28.40	$37,826
B. Required activities												520
Initial Performance test d,e	40	1	40	0	0	0	0	$0	<- One time test required for new units.
Startup, shutdown, malfunction plan f	N/A										Note: We estimate that there are 142 refineries (major sources) with 520 units. This includes 101 sources with 116 FCCU units, 114 sources with 151 CRU units, and 105 sources with 253 SRU units. Of sources with SRU units, we assume 27 sources are using CEMS on 65 units.
PM Performance Test (internal)g	40	1	40	50.3	2010.67	100.53	201.07	$267,801
HCN Performance Test (internal) d,e,h	40	1	40	0	0.0	0.0	0.0	$0	<- One time test required by 8/15/2017 rule.
Operating, maintenance, and monitoring plan d	40	1	40	0	0	0	0	$0
Revise operating, maintenance and monitoring plan i	20	1	20	0	0	0	0	$0
RATA for units using CEMs j	40	1	40	65	2600	130	260	$346,294
C. Create information	See 3B
D. Gather existing information	See 3B
E. Write report
Notification of construction/ reconstruction	2	1	2	0	0	0	0	$0
Notification of actual startup	2	1	2	0	0	0	0	$0
Notification of special compliance requirements	N/A
Notification of performance test d,e	2	1	2	0	0	0.00	0.00	$0	<- One time test required for new units.
Notification of PM performance test g	2	1	2	50.3	101	5	10	$13,390
Notification of HCN performance test h	2	1	2	0	0	0	0	$0	<- One time test required by 8/15/2017 rule.
Notification of compliance status d	4	1	4	0	0	0	0	$0
Extended compliance request	N/A
Report of performance test d	See 3B
Semiannual compliance reports k	10	2	20	142	2840	142	284	$378,260
Subtotal for Reporting Requirements					9,010			$1,043,570
4. Recordkeeping Requirements
A. Familiarize with rule requirements	See 3A
B. Plan activities	See 3B
C. Implement activities	See 3B
D. Develop record system l	N/A
E. Time to enter information m, n
Records of operations o	1	52	52	142	7384	369.2	738.4	$983,475
F. Time to train personnel d, p	4	1	4	0	0	0	0	$0	<- Line included a one time requirement from 8/15/2017 rule.
G. Time to adjust existing ways to comply with previously applicable requirements	N/A					0
H. Time to transmit or disclose information o	0.25	1	0.25	142	35.5	1.78	3.55	$3,459
I. Time for audits	N/A
Subtotal for Recordkeeping Requirements					8,532			$986,934
TOTAL LABOR BURDEN AND COST (rounded)q					17,500			$2,030,000		37.6	hr/response
Total Capital/O&M Costs (rounded)q								$8,780,000
Grand Total (Labor and Capital/O&M Costs)(rounded)q								$10,800,000
Assumptions:
a We have determined that 142 major petroleum refineries will have one or more affected facilities subject to the standard. This includes 101 sources with 116 FCCU. No new or reconstructed facilities are expected over the next 3 years.
b This ICR uses the following labor rates: $141.06 per hour for Executive, Administrative, and Managerial labor; $120.27 per hour for Technical labor, and $58.67 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2019, "Table 2. Civilian Workers, by Occupational and Industry group." 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 will refamiliarize themselves with the Subpart UUU rule during the upcoming 3-year ICR period.
d We have assumed that this activity is a one-time activity that applies only to new sources.
e We have assumed that this activity has already occurred for existing sources.
f As a result of the December 2015 final rule amendments, the startup, shutdown and malfunction (SSM) exemption has been eliminated. Therefore, this requirement is no longer relevant, and can be removed from future ICR supporting statements.
g The 2015 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 so each year, approximately 50.3 performance tests will be conducted (116 units / 3 years + 116 × 0.1 = 50.3 tests/year.
h The 2015 final rule required each catalytic cracking unit to conduct a one-time EPA Reference Method 320 test for HCN by August 1, 2017, or within 150 days of startup of a new unit. Therefore, it is assumed that this activity applies only to new units.
i The 2015 final rule assumed approximately 101 facilities must revise the OMM Plan due to monitoring requirement changes for catalytic cracking unit catalyst regeneration; assumed 20 hrs to revise the OMM Plan as a one-time activity.
j We assume that the burdens associated with RATA testing are roughly equal to those for a performance test (excluding the advance notice requirements). We also assume that there are 105 respondents with 253 SRU units (2.41 units/respondent). There are 27 respondents with SRUs using CEMs. Therefore, the number of SRUs using CEMs is 27 x 2.4 = 65 (rounded).
k We have assumed that all sources would be submitting semiannual compliance reports.
l We have assumed that these sources will have the record system in place to monitor operations.
m We have assumed that depending on the compliance option for the affected facility (i.e., catalytic cracking unit, sulfur recovery units, and by-pass lines) selected by the respondent and the size of the catalytic cracking unit and control device used (e.g., wet scrubber, electrostatic precipitator and thermal incinerators), sources are required to either install continuous opacity monitoring systems and/or continuous parameter monitoring, or choose an alternative option for parameter monitoring.
n We have assumed that all respondents would have to keep records of their operations according to the operation and maintenance plan.
o We have assumed that it will take each respondent approximately one hour to record data per week (52 weeks) and 15 minutes to transmit it semiannually.
p 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 2015 final rule. Therefore, it is assumed that this activity now applies only to new units.
q 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 – NESHAP for Petroleum Refineries: Catalytic Cracking Units, Catalytic Reforming Units, and Sulfur Recovery Units (40 CFR Part 63, Subpart UUU) (Renewal)
					49.44	66.62	26.75
Activity	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Hours per occurrence	Number of occurrence per plant-year	Hours per plant per year (C=AxB)	Plants per year	Technical person-hours per year (E=CxD)	Management person-hours per year (Ex0.05)	Clerical person-hours per year (Ex0.1)	Total Cost per Year $a		Type of affected unit	Number of respondents	Number of Units
Report Review										FCCU	101	116
Notification of construction/reconstruction	N/A									CRU	114	151
Notification of actual startup	N/A									SRU	105	253
Notification of special compliance requirements	N/A
Notification of performance test b	2	1	2	0	0	0	0	$0
Notification of PM performance test c	2	1	2	50.3	100.53	5.03	10.05	$5,574.17
Notification of HCN performance test d	2	1	2	0	0	0	0	$0
Notification of compliance status	2	1	2	0	0	0	0	$0
Review of operation, maintenance, and monitoring plan b	4	1	4	0	0	0	0	$0
Review of revised operation, maintenance, and monitoring plan e	2	1	2	0	0	0	0	$0
Review of repeat performance test report	8	1	8	0	0	0	0	$0
Review of RATA for CEMS f	8	1	8	65	520	26	52	$28,831.92	<-New line item, should have been included in prior ICR
Review of compliance report	N/A
Review of semiannual compliance reports g	2	2	4	142	568	28.4	56.8	$31,493.33
Review of NESHAP waiver application	4	1	4	0	0	0	0	$0
TOTAL ANNUAL BURDEN AND COST (rounded)h					1,370			$65,900
Assumptions:
a This cost is based on the following labor rates: Managerial rate of $66.62 (GS-13, Step 5), Technical rate of $49.44 (GS-12, Step 1), and Clerical rate of $26.75 (GS-6, Step 3). These rates are from the Office of Personnel Management (OPM) 2019 General Schedule which excludes locality rates of pay. The rates have been increased by 60 percent to account for the benefit package available to government employees.
b We have assumed that this activity is a one-time activity that applies only to new sources.
c The 2015 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, so each year, approximately 50.3 performance tests will be conducted (116 units / 3 years + 116 × 0.1 = 50.3 tests/year.
d The 2015 final rule required each catalytic cracking unit to conduct a one-time EPA Reference Method 320 test for HCN by August 1, 2017, or within 150 days of startup of a new unit. Therefore, it is assumed that this activity applies only to new units.
e The 2015 final rule assumed approximately 101 facilities must revise the OMM Plan due to monitoring requirement changes for catalytic cracking unit catalyst regeneration; assumed 2 hrs to review the OMM Plan as a one-time activity.
f We assume that the burdens associated with review of RATA testing are roughly equal to those for review of a performance test. We also assume that there are 105 respondents with 253 SRU units (2.41 units/respondent). There are 27 respondents with SRUs using CEMs. Therefore, the number of SRUs using CEMs is 27 x 2.4 = 65 (rounded).
g We have assumed that all sources would be submitting semiannual compliance reports.
h Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: O&M

Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A)	(B)	(C)	(D)	(E)	(F)	(G)
Continuous Monitoring Device	Capital/Startup Cost for One Respondent	Number of New Respondents	Total Capital/Startup Cost,	Annual O&M Costs for One Respondent	Number of Respondents with O&M	Total O&M,
			(B X C)			(E X F)
COMS a (FCCUs)	$95,700	0	$0	$28,600	25	$715,000
CPMS b (FCCUs)	$18,900	0	$0	$25,350	76	$1,926,600
CPMS (CRUs)	$0	0	$0	$17,940 c	151c	$2,708,940
CPMS (SRUs)	$74,000	0	$0	$26,000	78	$2,028,000
CEMS d (SRUs)	$150,000	0	$0	$34,840	27	$940,680
PM Performance Test (outsourced) e	$0	0	$0	$9,200	50.3	$462,760
HCN Performance Test (outsourced) f	$0	0	$0	$10,000	0	$0
TOTAL g			$0			$8,780,000
Note: We estimate that there are 142 refineries (major sources) with 520 units. This includes 101 sources with 116 FCCU units, 114 sources with 151 CRU units, and 105 sources with 253 SRU units.
a COMS – continuous opacity monitoring system
b CPMS – continuous parametric monitoring system
c We estimate that there are 151 CRUs using CPMS for monitoring, with an O&M cost of $17,940 per CPMS.
d CEMS – continuous emission monitoring system. We assume 27 sources with SRU units are using CEMS on 65 units.
e The 2015 final rule amendments required facilities with FCCU to conduct EPA Reference Method (M5) PM testing every 5 years, unless the “NSPS J” compliance option is used (i.e., the fixed 20 percent opacity operating limit compliance alternative), and the PM emissions rate during the most recent test is greater than 0.8 g PM/kg coke burn-off, in which case the testing frequency will be annually. It was assumed that approximately 10% of sources will require annual testing. In the upcoming 3-year ICR period, we assume that a total of 50.3 units per year will need to have a PM performance test (116 units/3 years + 116 × 0.1 = 50.3). We assume it costs $9,200 per unit to conduct a EPA Method 5 performance test.
f The 2015 final rule amendments required a one-time performance test for HCN for catalytic cracking unit catalyst regeneration by August 1, 2017, or within 150 days of startup of a new unit. Therefore, it is assumed that this activity applies only to new units. We assume it costs $10,000 per unit to conduct a EPA Method 320 performance test.
g Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 4: Responses

Total Annual Responses
(A)	(B)	(C)	(D)	(E)
Information Collection Activity	Number of Respondents	Number of Responses	Number of Existing Respondents That Keep Records But Do Not Submit Reports	Total Annual Responses
				E=(BxC)+D
Notification of particulate matter performance test	50.3a	1.15c	0	57.845
Notification of HCN performance test	0b	1.15c	0	0
Operation, maintenance, and monitoring plan	0d	1	0	0
Particulate matter performance test reports	50.3a	1.15c	0	57.845
HCN performance test reports	0b	1.15c	0	0
Engineering assessment for evaluation of catalytic reforming unit operational requirements	0e	1	0	0
Notification of performance test f	0	1	0	0
Semiannual compliance report	2	142	0	284
Relative accuracy test audits for units using CEMs	27	2.41 g	0	65.07
			Total	465