Burden Calculation Tables

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Overview

Respondents
Agency
O&M

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Sheet 1: Respondents

Table 1: Annual Respondent Burden and Cost – NSPS for Petroleum Refineries (40 CFR Part 60, Subpart J) (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) Total Cost per year b
1. Applications	N/A							$0		Labor Rates
2. Survey and Studies	N/A							$0		Management	$149.84
3. Reporting requirements								$0		Technical	$122.66
A. Familiarize with Regulatory Requirements c	1	1	1	130	130	6.5	13	$17,711.20		Clerical	$60.88
B. Required activities								$0
Performance Tests								$0
a. Relative Accuracy Test Audit d	146	2	292	0	0	0	0	$0
b. CEMS audits (RAA or CGA) e	160	3	480	0	0	0	0	$0
C. Create information	See 3B
D. Gather existing information	See 3B
E. Write Reports
i. Notification of construction /reconstruction f	2	1	2	0	0	0	0	$0
ii Notification of performance test f	2	1	2	0	0	0	0	$0
iii. Report of performance test f	2	1	2	0	0	0	0	$0
iv. Semiannual emission reports g	2	2	4	130	520	26	52	$70,844.80
Subtotal for Reporting Requirements					748			$88,556
4. Recordkeeping requirements
A. Familiarize with Regulatory Requirements	See 3A
B. Plan activities	See 3A
C. Implement Activities	See 3B
D. Develop record system	N/A
E. Time to enter information
Records of Operating Parameters h	0.25	350	87.5	130	11,375	568.75	1,137.5	$1,549,730.00
F. Time to train personnel	N/A
G. Time for audits	N/A
Subtotal for Recordkeeping Requirements					13,081			$1,549,730
TOTAL LABOR BURDEN AND COSTS (rounded) i					13,800			$1,640,000		# Responses	Hrs/response
TOTAL CAPITAL AND O&M COST (rounded) i								$809,000		260	53
GRAND TOTAL (rounded) i								$2,450,000
Assumptions:
a We have assumed that there are approximately 130 respondents, with no additional new, modified or reconstructed sources becoming subject to NSPS Subpart J over the next three years since any of these events would trigger NSPS Subpart Ja applicability. In addition, we have assumed that there is an average of one affected facility subject to Subpart J at each petroleum refinery plant.
b This ICR uses the following labor rates: $149.84 per hour for Executive, Administrative, and Managerial labor; $122.66 per hour for Technical labor, and $60.88 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2020, Table 2. Civilian Workers, by Occupational and Industry groups. 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 each respondent will have to familiarize with the regulatory requirements each year. This is estimated to take one hour.
d We have assumed that the CEMS accuracy assessment (i.e., relative accuracy test or RATA) are conducted twice a year and take 146 hours per response. It is assumed that the RATA are typically conducted at the same time as the CGA to save costs. However, all respondents are estimated to comply with the CEMS requirements of 40 CFR Part 60, Subpart Ja and therefore there is no burden associated with this requirement under Subpart J.
e We have assumed that CEMS audits (Relative Accuracy Audits or Cylinder Gas Audits) are conducted three times per year (Appendix F of Part 60 allows for 3 of 4 quarters, but no more than three quarters in succession) and will take 160 hours per occurrence. We have assumed that each respondent has at least one monitor for each parameter requiring monitoring under the standards. However, all respondents are estimated to comply with the CEMS requirements of 40 CFR Part 60, Subpart Ja and therefore there is no burden associated with this requirement under Subpart J.
f One-time requirement. Not applicable during this year.
g We have assumed that it will take two hours for each respondent to write semiannual emissions reports twice per year.
h We have assumed that each respondent will take 0.25 hours per day, and an estimated operational schedule of 350 days per year to enter records of operating parameters.
i Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 2: Agency

Table 2: Average Annual EPA Burden and Cost – NSPS for Petroleum Refineries (40 CFR Part 60, Subpart J) (Renewal)
Activity	(A) EPA person-hours per occurrence	(B) No. of occurrences per plant per year	(C) EPA person hours per plant per year (AxB)	(D) Plants per year a	(E) Technical person-hours per year (CxD)	(F) Management person-hours per year (Ex0.05)	(G) Clerical person-hours per year (Ex0.1)	(H) Cost, $ b
1. Review reports										Labor Rates
a. Notification of construction/reconstruction c	0.5	1	0.5	0	0	0	0	$0		Management	$69.04
b. Notification of performance test d	0.5	1	0.5	0	0	0	0	$0		Technical	$51.23
c. Semiannual emission reports e	1.5	2	3	130	390	19.5	39	$22,407.45		Clerical	$27.73
TOTAL (rounded) f					449			$22,400
Assumptions:
a We have assumed that there are approximately 130 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three years. In addition, we have assumed that there is an average one affected facility subject to Subpart J at each petroleum refinery plant.
b This cost is based on the following hourly labor rates times a 1.6 benefits multiplication factor to account for government overhead expenses: $69.04 for Managerial, $51.23 for Technical and $27.73 Clerical. These rates are from the Office of Personnel Management (OPM) “2021 General Schedule” which excludes locality rates of pay.
c We have assumed that it will take 0.5 hours once a year to review report from new sources; however there are no new sources estimated.
d We have assumed that it will take 0.5 hours once a year to review performance test report from new sources; however there are no new sources estimated.
e We have assumed that it will take 1.5 hours, twice per year, to review the excess emission reports.
f 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, (B X C)	Annual O&M Costs for One Respondent	Number of Respondents with O&M	Total O&M, (ExF)		CEPCI values		Device	Capital/Startup Cost for One Respondent (Year 2000)	Annual O&M Costs for One Respondent (Year 2000)
Opacity	$33,808	0	$0	$1,691	130	$219,787		468.2	2005	Opacity	$26,056	$1,303
CO	$11,480	0	$0	$1,148	130	$149,280		607.5	2019	CO	8,848	$885
SO2/H2S	$16,904	0	$0	$1,691	130	$219,787				SO2/H2S	13,028	$1,303
O2	$7,924	0	$0	$1,691	130	$219,787				O2	6,107	$1,303
Total			$0			$809,000
a Costs are based on the EPA Cost Control Manual (Sixth Edition, EPA/452/B-02-001), adjusted using the Chemical Engineering Index for process instruments from 2005 to 2019.
b Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
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	130	0	0	130
2	0	130	0	0	130
3	0	130	0	0	130
Average	0	130	0	0	130
1 New respondents 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 or modification	0	1	0	0
Notification of performance test	0	1	0	0
Report of performance test	0	1	0	0
Semiannual report	130	2	0	260
			Total	260