Burden Calculation Tables

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Overview

Table 1
Table 2
Capital O&M

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Sheet 1: Table 1

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)
Burden Item	(A) Person-hours per occurrence	(B) Number of occurrences per year per respondent a	(C) Person-hrs. per respondent per year (C=AxB)	(D) Respondents per year b	(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
1. Applications	N/A									Labor Rates:
2. Survey and Studies										Management	$153.55
A. Flare Management Plan	160	1	160	0	0	0	0	$0		Technical	$122.20
B. Flare Management Plan Revision b	8	1	8	28	224	11	22	$30,470		Clerical	$61.51
C. Root Cause Analysis (flow)	45	4	180	129	23,220	1,161	2,322	$3,158,581.77
D. Root Cause Analysis (sulfur)	24	3	72	129	9,288	464	929	$1,263,432.71
3. Reporting Requirements
A. Familiarize with rule requirements	1	1	1	129	129	6.5	13	$17,547.7
B. Required Activities
Initial performance tests on new facilities d	40	1	40	86	3,440	172	344	$467,938.04
Repeat of initial performance tests on new facilities e	40	0.05	2	86	172	8.6	17	$23,396.90
Initial CEMS Audits (RAA or CGA) new facilities f	36	1	36	86	3,096	155	310	$421,144.24
CEMS Audits (RAA or CGA) existing facilities g	36	8.9	320	129	41,220	2,061	4,122	$5,607,094.77
Initial Relative Accuracy Test new facilities f	24	6	144	86	12,384	619	1,238	$1,684,576.94
Relative Accuracy Test existing facilities g	24	43.3	1040	129	134,112	6,706	13,411	$18,243,054.19
Initial CPMS Audits (RAA or CGA) new facilities f	36	4	144	86	12,384	619	1,238	$1,684,576.94
CPMS Audits (RAA or CGA) existing facilities g	36	25.6	920	129	118,728	5,936	11,873	$16,150,391.75
C. Create Information	See 3B
D. Gather Existing Information	See 3E
E. Write Report h
Notification of construction, reconstruction, or modification	2	1	2	86	172	9	17	$23,396.90
Notification of anticipated startup	2	1	2	86	172	9	17	$23,396.90
Notification of actual startup	2	1	2	86	172	9	17	$23,396.90
Notification of initial performance test	2	1	2	86	172	9	17	$23,396.90
Report of performance test	See 3B
Semiannual Emissions Reports i	16	2	32	129	4,128	206	413	$561,525.65
Subtotal for Reporting Requirements					417,695			$49,407,320
4. Recordkeeping Requirements
A. Familiarize with rule requirements	See 3A
B. Plan Activities	See 3B
C. Implement Activities	See 3B
D. Develop Record System	N/A
E. Time to Enter Information
Records of operating parameters j	0.25	350	87.5	129	11,288	564	1,129	$1,535,421.69
F. Train Personnel	N/A
G. Audits	N/A									716	# responses
Subtotal for Recordkeeping Requirements					12,981			$1,535,422		602	hr/response
Total Labor Burden and Costs (rounded) k					431,000			$50,900,000
Total Capital and O&M Cost (rounded) k								$120,000,000
GRAND TOTAL (rounded) k								$171,000,000
Assumptions
a Occurrences per respondent per year is calculated as the number of affected facilities (flares, FCCU, FCU, FGCD, sulfur plant) times the occurrences 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.
b Assume that there are approximately 129 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 129 petroleum refineries will become subject to the provisions of Subpart Ja over the three-year period of this ICR (86 affected facilities per year) due to being constructed, reconstructed, or modified and that these facilities will have initial performance testing costs. We assume 28 of these reconstructed or modified facilities will be existing flares already subject to Subpart Ja and that they will re-submit a flare management plan.
c This ICR uses the following labor rates: Managerial $153.55 ($73.12+ 110%); Technical $122.20 ($58.19 + 110%); and Clerical $61.51 ($29.29 + 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2021, “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.
d We have assumed that it will take 40 hours for each respondent to perform initial performance tests.
e We have assumed that 5 percent of sources would have to repeat performance test due to failure.
f We assume that two facilities at each of the 129 petroleum refineries will become subject to the provisions of Subpart Ja over the three-year period of this ICR (86 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 one CPMS monitor is needed for each flare and one CEMS monitor and two CPMS monitors are needed for each other newly affected facility (i.e. FCCU, FCU, FGCD, Sulfur plant). 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.
g Subpart Ja requires regular relative accuracy evaluations of all monitors on existing affected facilities. We assume there are 8.9 CEMS at each refinery (341 flare CEMS + 804 other equipment CEMS)/129 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 21.6 CEMS and CPMS per refinery (341 flare CEMS + 341 flare CPMS + 804 other equipment CEMS + 1,308 other equipment CPMS)/129 refineries, that the relative accuracy test or RATA are conducted twice a year, and take 24 hours per monitor. We assume there are 12.8 CPMS at each refinery (341 flare CPMS + 1,308 other equipment CPMS)/129 refineries), that these CPMS are audited twice per year, and that these Relative Accuracy Audits or Cylinder Gas Audits take 36 hours.
h We have assumed that each respondent will take 2 hours to write report.
i We have assumed that each respondent will take 8 hours twice per year to complete semiannual reports
j Assume operation 350 days per year as specified in the NSPS review document.
k 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 – NSPS for Petroleum Refineries for which Construction, Reconstruction, or Modification Commenced After May 14, 2007 (40 CFR Part 60, Subpart Ja) (Renewal)
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
New Affected Facilities:										Labor Rates:
Report Review										Management	$69.04
Notification of construction, reconstruction, or modification c	2	1	2	86	172	8.6	17.2	$9,882		Technical	$51.23
Notification of anticipated startup d	0.5	1	0.5	86	43	2.15	4.3	$2,471		Clerical	$27.73
Notification of actual startup d	0.5	1	0.5	86	43	2.15	4.3	$2,471
Notification of performance test d	0.5	1	0.5	86	43	2.15	4.3	$2,471
Flare management plans e	1	1	1	28	28	1.4	2.8	$1,609
Review performance test results	8	1	8	86	688	34	69	$39,529
Emission Reports	4.2	1	4.2	86	361	18	36	$20,753
Existing Plants:
Semiannual Emissions Reports f	4.2	2	8.4	129	1,084	54.18	108	$62,258.24
TOTAL (rounded) g					2,830			$141,000
Assumptions:
a Assume that there are approximately 129 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 129 petroleum refineries will become subject to the provisions of Subpart Ja over the three-year period of this ICR (86 affected facilities per year) due to being constructed, reconstructed, or modified and that these facilities will perform initial performance testing.
b This cost is based on the average hourly labor rate as follows: Managerial $69.04 (GS-13, Step 5, $43.15 + 60%); Technical $51.23 (GS-12, Step 1, $32.02 + 60%); and Clerical $27.73 (GS-6, Step 3, $17.33 + 60%). This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. These rates are from the Office of Personnel Management (OPM), 2021 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 We assume that the review of the 'Notification of construction, reconstruction, or modification' submitted by all sources with newly affected facilities (due to being constructed, reconstructed, or modified) will take 2 hours to complete.
d We assume that the review of the 'Notification of anticipated startup', 'Notification of actual startup', and 'Notification of performance test' submitted by all sources with newly affected facilities (due to being constructed, reconstructed, or modified) will each take 0.5 hours to complete.
e Some flare management plans will need more review than others, depending on complexity of flare connections and baseline calculations. We assume 1 hour is the average amount of time spent per plan.
f We have assumed that all existing plants will be required to complete semiannual emissions reports.
g Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: Capital 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 a	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	86	129	0	86	129
2	86	129	0	86	129
3	86	129	0	86	129
Average	86	129	0	86	129
a New respondents include sources with constructed, reconstructed and modified affected facilities. We assume 2 facilities per refinery will modify and become subject to Subpart Ja during the three-year period of this ICR. ( 2 x 129 refineries = 258 facilities/3 years = 86 facilities per year). Based on U.S. EIA data for the number of operating refineries in 2021 (https://www.eia.gov/dnav/pet/pet_pnp_cap1_dcu_nus_a.htm) and correspondence with API, we assume there are 129 refineries subject to Subpart Ja.
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
Initial notification of construction/ reconstruction	86	1	0	86
Notification of anticipated startup	86	1	0	86
Notification of actual startup	86	1	0	86
Notification of performance test	86	1	0	86
Flare management plan a	28	1	0	28
Performance test results	86	1	0	86
Semiannual reports of excess emission	129	2	0	258
			Total	716
a We assume 2 facilities per refinery will modify or reconstruct and become subject to Subpart Ja during the three-year period of this ICR ( 2 x 129 refineries = 258 facilities/3 years = 86 facilities per year). Based on data collected in the prior ICR (ICR No. 2263.06), we assume that 32% of the modified/reconstructed facilities are flares (86 facilities per year x 32% = 28 flares per year). These flare facilities will need to re-submit a flare management plan.
									2263.06
Capital/Startup vs. Operation and Maintenance (O&M) Costs									Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A)	(B)	(C)	(D)	(E)	(F)	(G)			(A)	(B)	(C)	(D)	(E)	(F)	(G)
Continuous Monitoring Device	Capital/ Startup Cost for One Respondent	Number of New Respondents a	Total Capital/ Startup Cost, (BxC)	Annual O&M Costs for One Respondent	Number of Respondents with O&M a	Total O&M, (ExF)			Continuous Monitoring Device	Capital/ Startup Cost for One Respondent a	Number of New Respondents a	Total Capital/ Startup Cost,	Annual O&M Costs for One Respondent a	Number of Respondents with O&M a	Total O&M,
New Affected Facilities b									New Affected Facilitiesb,c
H2S CEMS – Flares c, d, e	$358,000	0	$0	$59,700	0	$0			H2S CEMS – Flares	$372,000 d	16	$5,952,000	$62,000 e	32	$1,984,000
Flare Vent Flow CPMS c, d, e									Flare Vent Flow CPMS
CEMS – FCCU, FCU, FGCD, Sulfur plant f, g, h	$155,000	29	$4,495,000	$25,000	58	$1,450,000			CEMS – FCCU, FCU, FGCD, Sulfur plant f	$161,000 g	34	$5,474,000	$25,000 h	68	$1,700,000
CPMS – FCCU, FCU, FGCD, Sulfur plant f, i , j	$86,000	29	$2,494,000	$100,000	58	$5,800,000			CPMS – FCCU, FCU, FGCD, Sulfur plant f	$86,000 i	34	$2,924,000	$100,000 j	68	$6,800,000
Existing Affected Facilities									Existing Affected Facilitiesk
H2S CEMS – Flares d, e, k	$358,000	0	$0	$59,700	341	$20,357,700			H2S CEMS – Flares	$372,000 d	0	$0	$62,000 e	280	$17,360,000
Flare Vent Flow CPMS d, e, k									Flare Vent Flow CPMS
CEMS – FCCU, FCU, FGCD, Sulfur plant g, h, l	$155,000	0	$0	$25,000	804	$20,100,000			CEMS – FCCU, FCU, FGCD, Sulfur plant	$161,000 g	0	$0	$25,000 h	600	$15,000,000
CPMS – FCCU, FCU, FGCD, Sulfur plant i, l, m	$86,000	0	$0	$50,000	1308	$65,400,000			CPMS – FCCU, FCU, FGCD, Sulfur plant	$86,000 i	0	$0	$50,000 l	900	$45,000,000
Total n			$6,989,000			$113,107,700	$120,096,700		Total m		50	$14,400,000			$87,800,000
Footnotes:									Footnotes:
a In this table, the Number of New Respondents corresponds to the number of affected facilities (Flares, FCCU, FCU, FGCD, Sulfur plant) being constructed, re-constructed, or modified each year during this ICR period. In this table the Number of Respondents with O&M corresponds to newly affected facilities and existing affected facilities (Flares, FCCU, FCU, FGCD, Sulfur plant) complying with Subpart Ja.									a In this table, the number of respondents corresponds to: 1) the number of new affected facilities (Flares, FCCU, FCU, FGCD, Sulfur plant) being constructed, re-constructed, or modified each year during this ICR period, or 2) the number of existing affected facilities (Flares, FCCU, FCU, FGCD, Sulfur plant) already complying with Subpart Ja.
b Per comments received from API/AFPM for the ICR renewal 2263.06, we assume that two facilities at each of the 129 petroleum refineries are constructed, reconstructed, or modified over the three-year period of this ICR (258 facilities over three years or 86 new affected facilities per year). We assume that 50% of the affected facilities newly subject to Subpart Ja will have capital and startup costs.									b Per comments received from API/AFPM, we assume that two facilities at each of the 150 petroleum refineries become subject to the provisions of Subpart Ja over the three-year period of this ICR (300 facilities over three years or 100 new affected facilities per year) due to being constructed, reconstructed, or modified and that half of these new affected facilities will have capital and startup costs (50 facilities per year).
c Based on analysis of data in the previous ICR, EPA's Petroleum Refinery Database, and U.S. EIA's 2021 "Refinery Capacity Report", we assume that all flares at refineries are already subject to Subpart Ja and no existing or new flares will become subject to Subpart Ja during the three-year period of this ICR. Existing flares already subject to Subpart Ja that modify will not have capital/startup costs. O&M costs for these flares is shown under O&M Costs for Existing Affected Facilities.									c Based on the number of existing flare units, we assume that 32% of the new affected facilities are flares and that 68% of the new facilities are FCCU, FCU, FGCD, Sulfur Plant, or other process units.
d Assume that capital/startup costs for a new flare sulfur CEMS and flow monitor CPMS is $358,000 (Docket Document EPA-HQ-OAR-2007-0011-0289, page 11). Capital costs have been increased from 2006 to 2020 $ using the CEPCI Equipment Cost Index. Each flare has one H2S CEMs and one flow CPMS.
e Assume that the annual O&M costs of the flare sulfur CEMS and vent gas flow monitor is $59,700 (Docket Document EPA-HQ-OAR- 2007-0011-0289, page 11). Costs have been increased from 2006 to 2020 $ using the CEPCI Equipment Cost Index.									d Assume that capital/startup costs for a new flare sulfur CEMS and flow monitor CPMS is $372,000 (Docket Document EPA-HQ-OAR-2007-0011-0289, page 11). Capital costs have been increased from 2006 to 2018 $ using the CEPCI Equipment Cost Index.
f We assume that 68% of the newly affected facilities are FCCU, FCU, FGCD, Sulfur Plant, or other process units (86 facilities per year x 68% = 58 (rounded)). We assume that 50% of the affected facilities newly subject to Subpart Ja will have capital and startup costs (58 facilities x 50% = 29 facilities). Per comments received from API/AFPM for the ICR renewal 2263.06, we assume that each new affected FCCU, FCU, FGCD, or Sulfur plant requires one CEMS and two CPMS.									e Assume that the annual O&M costs of the flare sulfur CEMS and vent gas flow monitor is $62,000 (Docket Document EPA-HQ-OAR- 2007-0011-0289, page 11). Costs have been increased from 2006 to 2018 $ using the CEPCI Equipment Cost Index.
g Assume that capital/ startup costs for a new FCCU NOx analyzer are $155,000 (Docket Document EPA-HQ-OAR-2007-0011-0222, page 8). Capital costs have been increased from 2006 to 2020 $ using the CEPCI Equipment Cost Index.									f Per comments received from API/AFPM, we assume that each new affected source requires one CEMS and two CPMS.
h Per comments received from API/AFPM for the ICR renewal 2263.06, we assume that O&M cost for each CEMS includes daily checks of 30 minutes, preventative maintenance, and parts for a total cost of $25,000 per year.									g Assume that capital/ startup costs for a new FCCU NOx analyzer are $161,000 (Docket Document EPA-HQ-OAR-2007-0011-0222, page 8). Capital costs have been increased from 2006 to 2018 $ using the CEPCI Equipment Cost Index.
i Per comments received from API/AFPM for the ICR renewal 2263.06, we assume that capital/startup costs for a single CPMS monitor are $43,000 and there are two CPMS per newly affected FCCU, FCU, FGCD, or Sulfur plant affected facility.									h Per comments received from API/AFPM, we assume that O&M cost for each CEMS includes daily checks of 30 minutes, preventative maintenance, and parts for a total cost of $25,000 per year.
j Per comments received from API/AFPM for the ICR renewal 2263.06, we assume that annual O&M costs for a single CPMS are $50,000 and there are two CPMS per newly affected FCCU, FCU, FGCD, or Sulfur plant affected facility.									i Assume that capital/startup costs for a single CPMS monitor are $43,000 and there are two CPMS per new affected facility.
k Assumes that 70% (341) of the 487 existing flares at currently operating petroleum refineries are already subject to the provisions of Subpart Ja and each flare has one H2S CEMs and one flow CPMS. The other 30% of flares are expected to use the monitoring alternative for emergency flares and flares with flare gas recovery system. The number of flares at petroleum refineries (487) is derived by cross referencing the information in the "flares" table in the 2011 Petroleum Refinery Database (https://www.epa.gov/stationary-sources-air-pollution/comprehensive-data-collected-petroleum-refining-sector) with data from the U.S. Energy Information Administration's 'Refinery Capacity Report' (https://www.eia.gov/petroleum/refinerycapacity/), which shows the 129 refineries operating as of January 1, 2021.									j Assume that annual O&M costs for a single CPMS are $50,000 and there are two CPMS per new affected facility.
l The number of existing affected facilities subject to Subpart Ja has been increased from the number shown in the previous ICR renewal (2263.06) by three years of new and modified facilities. For CEMS units, this is 3 x 68 and for CPMS units, this is 3 x 68 x 2, as there are 2 CPMS units for each new affected facility.									k Assumes that 70% (280) of the 400 flares at petroleum refineries are already subject to the provisions of Subpart Ja and each has one H2S CEMs and one flow CPMS. The other 30% of flares are expected to use the monitoring alternative for emergency flares and flares with flare gas recovery system. For other existing affected facilities (FCCU, FCU, FGCD, Sulfur Plant, or other process unit), we assume there are 4 CEMS and 6 CPMS at each petroleum refinery, for a total of 600 CEMS (4 x 150 = 600) and 900 (6 x 150) CPMS.
m Assume that annual O&M costs for a single CPMS are $50,000.									l Assume that annual O&M costs for a single CPMS are $50,000.
n Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. Some double counting occurs due to counting costs for CEMS and CPMS separately.									m Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. Some double counting occurs due to counting costs for CEMS and CPMS separately.