Burden Calculations Table

---

Overview

Respondents
Agency
O&M

---

Sheet 1: Respondents

Table 1: Annual Respondent Burden and Cost – NSPS for VOC Emissions from Petroleum Refinery Wastewater Systems (40 CFR Part 60, Subpart QQQ (Renewal)
Burden item	(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)
1. Applications	N/A									2019 Labor Rates
2. Survey and Studies	N/A									Technical	$120.27
3. Reporting requirements										Management	$141.06
A. Familiarize with regulatory requirements c	2	1	2	149	298	15	30	$39,690.62		Clerical	$58.67
B. Required activities
Inspect drain systems d	2	12	24	149	3,576	179	358	$476,287.44
Inspect oil-water separators e	8	2	16	149	2,384	119	238	$317,524.96
Performance test f	330	1	330	0	0	0	0	$0
C. Create information	See 3B
D. Gather existing information	See 3E
E. Write report
Notification of construction/reconstruction f	2	1	2	0	0	0	0	$0
Notification of modification f	2	1	2	0	0	0	0	$0
Notification of actual startup f	2	1	2	0	0	0	0	$0
Initial certification of equipment and inspections f	2	1	2	0	0	0	0	$0
Initial inspection report detailing emission problems f	2	1	2	0	0	0	0	$0
Notification of initial performance test f	2	1	2	0	0	0	0	$0
Various notifications of intent f	2	1	2	0	0	0	0	$0
Demonstration for alternative operational or process parameter f	2	1	2	0	0	0	0	$0
Notification of delay in compliance f	2	1	2	0	0	0	0	$0
Semiannual report g	8	2	16	149	2,384	119	238	$317,524.96
Results of performance test	See 3B
Subtotal for Reporting Requirements					9,938			$1,151,028
4. Recordkeeping requirements
A. Familiarize with regulatory requirements	See 3A
B. Plan activities	N/A
C. Implement activities	N/A
D. Develop record system	N/A
E. Enter information	1.5	1	1.5	149	224	11	22	$29,767.97
F. Train personnel	N/A
G. Audits	N/A
Subtotal for Recordkeeping Requirements					257			$29,768
TOTAL LABOR BURDEN AND COSTS (rounded) h					10,200			$1,180,000
TOTAL CAPITAL AND O&M COSTS (rounded) h								$19,400		34.2	hr/response
GRAND TOTAL (rounded) h								$1,200,000
Assumptions:
a We have assumed that the average number of respondents that will be subject to the rule will be 149. There will be no additional new sources per year that will become subject to the rule over the three-year period of this ICR.
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 We have assumed that each respondent will read instructions one time per year.
d We have assumed that each respondent will take two hours to inspect drain systems twelve times per year.
e We have assumed that it will take eight hours for each respondent to inspect oil-water separators two times per year.
f This activity applies only to new or modified sources.
g We have assumed that each respondent will take eight hours to write the semiannual report two times per year.
h Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

---

Sheet 2: Agency

Table 2: Average Annual EPA Burden and Cost – NSPS for VOC Emissions from Petroleum Refinery Wastewater Systems (40 CFR Part 60, Subpart QQQ (Renewal)
Activity	(A) EPA Person- hours per occurrence	(B) No. of occurrences per plant per year	(C) EPA person- hours per respondent per year (C=AxB)	(D) Plants 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)
1. Report Review										Labor Rates
Notification of construction/reconstruction	2	1	2	0	0	0	0	$0		Technical	$49.44
Notification of modification	2	1	2	0	0	0	0	$0		Management	$66.62
Notification of actual startup	2	1	2	0	0	0	0	$0		Clerical	$26.75
Initial certification for equipment and inspections	2	1	2	0	0	0	0	$0
Initial inspection detailing emission problems	2	1	2	0	0	0	0	$0
Notification of various intent c	2	1	2	0	0	0	0	$0
Demonstration for alternative operational or process parameter	2	1	2	0	0	0	0	$0
Notification of delay in compliance	2	1	2	0	0	0	0	$0
Notification of initial performance test	2	1	2	0	0	0	0	$0
Initial performance test report for flares	2	1	2	0	0	0	0	$0
Review of semiannual reports d	8	2	16	149	2,384	119	238	$132,183.26
TOTAL COSTS (rounded)e					2,740			$132,000
Assumptions:
a We have assumed that the average number of respondents that will be subject to the rule will be 149. There will be no additional new sources that will become subject to the rule over the three-year period of this ICR.
b This ICR uses the following labor rates: $66.62 for managerial, $49.44 for technical, and $26.75 for clerical labor. 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 packages available to government employees.
c The following notification review is included: election to construct and operate a completely closed drain system; election to construct and operate a floating roof; intent to use an alternative means of emission limitation; and intent to use a VOC control device other than a carbon absorber to meet the requirements of 60.692-5(a).
d We have assumed that it will take 8 hours two times per year to review each semiannual report.
e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

---

Sheet 3: O&M

Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
	(A)	(B)	(C)	(D)	(E)
Year	Number of New Respondents 1	Number of Existing Respondents	Number of Existing Respondents that keep records but do not submit reports	Number of Existing Respondents That Are Also New Respondents	Number of Respondents (E=A+B+C-D)
1	0	149	0	0	149
2	0	149	0	0	149
3	0	149	0	0	149
Average	0	149	0	0	149
1 New respondent include sources with constructed, reconstructed and modified affected facilities.
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 construction/ reconstruction	0	1	N/A	0
Notification of modification	0	1	N/A	0
Notification of actual startup	0	1	N/A	0
Initial certification of equipment and inspections	0	1	N/A	0
Initial inspection report detailing emission problems	0	1	N/A	0
Notifications of various intent	0	1	N/A	0
Demonstration for alternative operational or process parameter	0	1	N/A	0
Notification of delay in compliance	0	1	N/A	0
Semiannual report	149	2	N/A	298
Notification of initial performance test	0	1	N/A	0
			Total	298		34	hr/response
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, (B X C)	Annual O&M Costs for One Respondent	Number of Respondents with O&M	Total O&M, (E X F)
Portable VOC analyzer for non-regenerative carbon absorber	$2,960	0	0	$130	149	$19,370