Burden Calculations Table

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Overview

Table 1
Table 2
O&M

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Sheet 1: Table 1

Table 1. Annual Respondent Burden and Cost - NESHAP for Petroleum Refineries (40 CFR Part 63, Subpart CC) (Renewal)
Burden Item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)	(I)	(J)
	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)	Installation, maintenance, and repair person-hours per year (F=CxD)	Plant operator person-hours per year (G=CxD)	Management person-hours per year (Ex0.05)	Clerical person hours per year (Ex0.1)	Cost b $
1. Applications	N/A											Labor Rates
2. Survey and studies	N/A											Management	Technical	Operator	Maintenance	Clerical
Process units -LDAR Evaluation of prevention measures c	8	13	104	0	0	N/A	N/A	0	0	$0		$152.73	$113.21	$76.63	$70.31	$48.72
Initial Flare Management Plan d	75	4	270	0	0	N/A	N/A	0	0	$0
Update the Flare Management Plan e	2	1	2.0	47	94	N/A	N/A	4.7	9.4	$11,817.65
3. Acquisition, installation, and utilization of technology and systems f
Technical	32	1	32	0	0	N/A	N/A	0	0	$0
Management	2	1	2	0	0	N/A	N/A	0	0	$0
4. Reporting requirements
A. Familiarization with rule requirementsg, h
Initial: i
i. General/applicability	20	1	20	14.2	284	N/A	N/A	14	28	$35,704.38
ii. Storage vessels	20	12	240	14.2	3,408	N/A	N/A	170	341	$428,452.57
iii. Process units – LDAR	20	11	220	14.2	3,124	N/A	N/A	156	312	$392,748.19
iv. Process vents	20	9	180	14.2	2,556	N/A	N/A	128	256	$321,339.43
Periodic: j
i. General/applicability	4	1	4	142	568	N/A	N/A	28	57	$71,408.76
ii. Storage vessels	2	12	24	142	3,408	N/A	N/A	170	341	$428,452.57
iii. Process units – LDAR	2	11	22	142	3,124	N/A	N/A	156	312	$392,748.19
iv. Process vents	2	9	18	142	2,556	N/A	N/A	128	256	$321,339.43
v. Heat exchange systems	2	3	6	142	852	N/A	N/A	43	85	$107,113.14
vi. Relief valves, bypass lines, delayed cokers, flares k	8	1	8	142	1,136	N/A	N/A	57	114	$142,817.52
B. Required activities g, h
Initial:
i. General/applicability	10	1	10	14.2	142	N/A	N/A	7.1	14	$17,852.19
ii. Storage vessels	88	12	1056	14.2	14,995	N/A	N/A	750	1500	$1,885,191.30
iii. Process units – LDAR	8	11	88	14.2	1,250	N/A	N/A	62	125	$157,099.27
iv. Process vents – initial performance test l	11	4	44	14.2	625	N/A	N/A	31	62	$78,549.64
v. Process vents – repeat performance test l	11	4	44	0.71	31	N/A	N/A	1.6	3.1	$3,927.48
Periodic:
i. General/applicability	3	1	3	142	426	N/A	N/A	21	43	$53,556.57
ii. Storage vessels	4	12	48	142	6,816	N/A	N/A	341	682	$856,905.13
iii. Process units – LDAR	1	11	11	142	1,562	N/A	N/A	78	156	$196,374.09
iv. Process vents	2	9	18	142	2,556	N/A	N/A	128	256	$321,339.43
v. Heat exchange systems – sampling analysis m
Technical	1	36	36	142	5,112	N/A	N/A	N/A	N/A	$578,734.63
Plant operator	3	36	108	142	N/A	N/A	15,336	N/A	N/A	$1,175,182.34
vi. Heat exchange systems – triggered monitoring of leak n
Technical	1	2	2	142	284	N/A	N/A	N/A	N/A	$32,151.92
Plant operator	3	2	6	142	N/A	N/A	852	N/A	N/A	$65,287.91
vii. Heat exchange systems – leak repair o	40	2	80	142	N/A	11,360	N/A	N/A	N/A	$798,698.88
Required Activities: p
i. Fenceline monitoring - small facility q	7.4	26	192	84	16,162	N/A	N/A	808	1,616	$2,031,830.70
ii. Fenceline monitoring - medium facility q	9.8	26	255	27	6,880	N/A	N/A	344	688	$864,900.90
iii. Fenceline monitoring - large facility q	11.6	26	302	31	9,350	N/A	N/A	467	935	$1,175,428.44
iv. Develop alternative monitoring plan for fenceline monitoring r	40	1	40	0	0	N/A	N/A	0	0	$0
v. Storage vessel inspections s	variable	variable	2.66	142	378	N/A	N/A	19	38	$47,486.83
vi. Flares s	0.4	365	146	142	20,732	N/A	N/A	1,037	2,073	$2,606,419.78
C. Create information	See 4B
D. Gather existing information	See 4B
E. Write report g, h
Notification of compliance status t
i. Storage vessels	1	12	12	14.2	170	N/A	N/A	8.5	17	$21,422.63
ii. Process units – LDAR	4	11	44	14.2	625	N/A	N/A	31	62	$78,549.64
iii. Process vents	1	9	9	14.2	128	N/A	N/A	6.4	13	$16,066.97
iv. Heat exchange systems	1	3	3	14.2	43	N/A	N/A	2.1	4.3	$5,355.66
Notification of storage vessel inspections	1	12	12	14.2	170	N/A	N/A	8.5	17	$21,422.63
Notification of reconstruction – process vent control devices l	4	4	16	14.2	227	N/A	N/A	11	23	$28,563.50
Notification of performance tests g, h	See 4B
Notification of compliance status u
Storage vessels, delayed cokers	1	2.67	2.67	0	0	N/A	N/A	0	0	$0
Relief valves, flares	1	2	2	0	0	N/A	N/A	0	0	$0
Notification of storage vessel inspection	0.5	1	0.5	0	0	N/A	N/A	0	0	$0
Semiannual compliance reports v, w
i. General/applicability x	18	2	36	142	5,112	N/A	N/A	256	511	$642,678.85
ii. Storage vessels y	1	18	18	142	2,556	N/A	N/A	128	256	$321,339.43
iii. Storage vessels – seal gap failure z	3	2	6	142	852	N/A	N/A	43	85	$107,113.14
iv. Process units – LDAR aa	3	22	66	142	9,372	N/A	N/A	469	937	$1,178,244.56
v. Process vents bb	1.5	8	12	142	1,704	N/A	N/A	85	170	$214,226.28
vi. Heat exchange systems cc	2	6	12	142	1,704	N/A	N/A	85	170	$214,226.28
vii. Storage vessels dd	0.00511	2	0.01022	142	1	N/A	N/A	0.07	0.15	$182.45
viii. Relief valves dd	0.5	2	1	142	142	N/A	N/A	7	14	$17,852.19
ix. Bypass lines dd	0.075	2	0.15	142	21	N/A	N/A	1	2	$2,677.83
x. Delayed cokers dd	0.25	0.167	0.04175	142	6	N/A	N/A	0.3	1	$745.33
xi. Flares dd	1.5	2	3	142	426	N/A	N/A	21	43	$53,556.57
xii. Maintenance Vents dd	1	1	1	14.2	14	N/A	N/A	0.7	1	$1,785.22
Quarterly fenceline monitoring report ee	2	4	8	142	1,136	N/A	N/A	57	114	$142,817.52
Subtotal for Reporting Requirements					179,481					$18,669,686
5. Recordkeeping requirements
A. Read and understand rule requirements	See 4A
B. Plan activities g, h	See 4A
C. Implement activities g, h	See 4B
D. Develop record system ff
Initial:
i. Storage vessels	2	12	24	14.2	341	N/A	N/A	17	34	$42,845.26
ii. Process units – LDAR	75	11	825	14.2	11,715	N/A	N/A	586	1,172	$1,472,805.70
iii. Process vents	2	9	18	14.2	256	N/A	N/A	13	26	$32,133.94
Periodic:
i. Storage vessels	2	12	24	142	3,408	N/A	N/A	170	341	$428,452.57
ii. Process units – LDAR	75	11	825	142	117,150	N/A	N/A	5,858	11,715	$14,728,057.00
iii. Process vents	2	9	18	142	2,556	N/A	N/A	128	256	$321,339.43
iv. Heat exchange systems gg
Technical	12	12	144	142	20,448	N/A	N/A	N/A	N/A	$2,314,938.53
Plant operator	12	12	144	142	N/A	N/A	20,448	N/A	N/A	$1,566,909.79
E. Time to enter and transmit information
Initial: h
i. Storage vessels	6	12	72	14.2	1,022	N/A	N/A	51	102	$128,535.77
ii. Process units – LDAR	99	11	1089	14.2	15,464	N/A	N/A	773	1,546	$1,944,103.52
iii. Process vents l	12	4	48	14.2	682	N/A	N/A	34	68	$85,690.51
Periodic: hh
i. Storage vessels	3.5	12	42	142	5,964	N/A	N/A	298	596	$749,791.99
ii. Process units – LDAR	99	11	1089	142	154,638	N/A	N/A	7,732	15,464	$19,441,035.24
iii. Process vents	29	4	116	142	16,472	N/A	N/A	824	1,647	$2,070,854.07
iv. Heat exchange systems	1	3	3	142	426	N/A	N/A	21	43	$53,556.57
Time to enter information ii
Storage vessels	variable	variable	4.09	142	581	N/A	N/A	29	58	$73,015.46
Relief valves	0.5	3.2	2	142	227	N/A	N/A	11	23	$28,563.50
Bypass lines	0.355	0.211	0.075	142	11	N/A	N/A	0.5	1.1	$1,337.22
Fenceline monitoring	0.5	26	13	142	1,846	N/A	N/A	92	185	$232,078.47
Delayed cokers	0.0167	501	8.4	142	1,188	N/A	N/A	59	119	$149,363.92
Flares	0.05	365	18.3	142	2,592	N/A	N/A	130	259	$325,802.47
Maintenance Vents	1	1	1	14.2	14	N/A	N/A	0.7	1.4	$1,785.22
Maintenance Vents - <72 lb/day	0.1	1	0.1	142	14	N/A	N/A	0.7	1.4	$1,785.22
F. Time to train personnel jj
Initial:
i. Storage vessels	1	12	12	14.2	170	N/A	N/A	8.5	17	$21,422.63
ii. Process units – LDAR	1	11	11	14.2	156	N/A	N/A	7.8	16	$19,637.41
iii. Process vents	1	4	4	14.2	57	N/A	N/A	2.8	5.7	$7,140.88
Periodic:
i. Storage vessels	N/A
ii. Process units – LDAR	0.5	11	5.5	142	781	N/A	N/A	39	78	$98,187.05
iii. Process vents	1	4	4	142	568	N/A	N/A	28	57	$71,408.76
iv. Heat exchange systems kk	2	10	20	142	2,840	N/A	N/A	142	284	$357,043.81
v. Training ll	8.5	1	8.5	142	1,207	N/A	N/A	60	121	$151,743.62
Subtotal for Recordkeeping Requirements					434,593					$46,921,366
Total Labor Burden and Cost (rounded) mm					614,000					$65,600,000		156	hr/response
Total Capital and O&M Cost (rounded) mm										$32,600,000
Grand TOTAL (rounded) mm										$98,000,000
Assumptions:
a. We estimate there are 142 existing petroleum refineries in the U.S. subject to NESHAP subpart CC, based on recent Agency data gathered through an ICR collection request under Section 114 of the CAA. We assume that no new refineries will become subject to this regulation. Furthermore, we estimate that a refinery has the following affected units: 12 Group 1 storage vessels subject to regulation; 11 process units subject to LDAR provisions; 9 process vents requiring monitoring, recordkeeping, and reporting; and 3 heat exchange systems subject to a monthly sampling program for VOC leak detection and repair, as well as recordkeeping and reporting requirements to ensure compliance with the program.
b. This ICR uses the following labor rates: $152.73 per hour for Executive, Administrative, and Managerial labor; $113.21 per hour for Technical labor, $76.63 per hour for plant operators; $70.31 per hour for installation, maintenance, and repair; and $48.72 per hour for Clerical labor. The labor rates are from the United States Department of Labor, Bureau of Labor Statistics, "May 2019 National Industry-Specific Occupational Employment Wage Estimates" for NAICS code 324100 - Petroleum and Coal Products Manufacturing. The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry.
c. The 2015 amendments included a one-time requirement for respondents to evaluate the prevention measures for affected pressure relief devices.
d. New refineries are required to develop a Flare Management Plan, and existing refineries were required to submit a Flare Management Plan by January 30, 2019.
e. Assume all respondents have submitted the Flare Management Plan by January 30, 2019. Assume one-third of all respondents (142/3 = 47) make periodic updates to the Plan each year, and that the update takes 2 hours.
f. The labor estimates are based on an EPA Maximum Achievable Control Technology (MACT) floor cost analysis, which estimates the planning burden for a single heat exchange system to be 32 hours for technical labor and 2 labor hours for management.
g. We assume that initial notifications and periodic reporting requirements for existing sources are accounted for in other existing NSPS and NESHAP regulations for equipment leaks, wastewater, storage tanks, and heat exchangers. This ICR only addresses the additional industry burden associated with rule requirements for the compliance reports.
h. Only new respondents or respondents that reconstruct units must comply with initial monitoring, recordkeeping, and reporting requirements for existing units, including initial notifications; design analysis and establishment of operating parameters for storage vessels; LDAR initial requirements; initial performance testing for process vents routed to a control device; heat exchanger requirements; and development of startup and malfunction plans and record systems for each unit. We estimate that existing refineries will reconstruct 10 percent of their existing units (i.e., 12 storage vessels, 11 process units, 9 process vents, 3 heat exchange systems, or 3.8 flares per refinery).
i. Respondents having new, modified, or reconstructed units must comply with initial requirements. The occurrence estimates are based on reading and understanding the rule requirements for each process unit/equipment that is modified.
j. We assume that each respondent will re-read the entire rule twice each year to re-familiarize with the applicability, monitoring, testing reporting and recordkeeping requirements for the equipment and process units.
k. These requirements were added in the 2015 amendments. We have assumed 8 hours per year for respondents to refamiliarize with these requirements.
l. We assume that 4 process vents per refinery are routed to control devices, and of which existing refineries will reconstruct 10 percent. We assume that 5 percent of respondents will have to repeat performance tests.
m. We assume all heat exchange systems at existing refineries are in compliance with the heat exchange system monitoring requirements promulgated in the 2009 rule amendment, but would need to meet the periodic requirements. We estimate the labor burden for setup of portable air stripping column and sampling/analysis for one heat exchange system to be 1 hour for technical labor and 3 labor hours for an operator. We assume there are 3 heat exchange systems per refinery, and that the event occurs 12 times per system per year, for a total of 36 occurrences per refinery per year.
n. We assume 2 events per year at each refinery, and estimate the labor burden for additional sampling and analysis triggered by leak monitoring to be 1 hour for technical labor and 3 labor hours for an operator.
o. We assume 2 events per year at each refinery, and estimate the labor burden to be 40 hours per repair.
p. These requirements are based on burden assumptions from the ICR for the 2015 amendment (ICR 1692.10).
q. These values are consistent with the Fenceline Monitoring Technical Support Document, located in Docket ID No. EPA-HQ-OAR-2010-0682.
r. This is a one-time requirement from the 2015 amendments.
s. These requirements for flare reporting are based on burden assumptions from the ICR for the 2015 amendment (ICR 1692.10).
t. New and existing refineries must submit notifications of compliance status for new or reconstructed units affected by the standard.
u. Notification of compliance status is a one-time response required by the 2015 amendment.
v. The rule requires that sources meet specific periodic requirements including: monitoring of storage vessels annually, LDAR monitoring of process units daily, monthly monitoring of process vents, recording of process parameters and monitoring results, and submittal of periodic semiannual compliance reports addressing each affected facility and performance test result.
w. Notifications related to construction/reconstruction and to periodic reporting for existing sources are accounted for in other existing NSPS and NESHAP regulations for equipment leaks, wastewater, storage tanks, and heat exchangers.
x. We assume 18 labor hours per occurrence, and that there will be 2 occurrences per refinery per year.
y. We assume 1 labor hour per occurrence, and that there will be 24 occurrences per respondent per year (12 Group 1 storage vessels/refinery x 2 occurrences/storage vessel/year).
z. We assume 3 labor hours per occurrence, and that there will be 2 occurrences per refinery per year.
aa. We assume 3 labor hours per occurrence, and that there will be 22 occurrences per respondent per year (11 process units/refinery x 2 occurrences/process unit/year).
bb. We assume 1.5 labor hours per occurrence, and that there will be 8 occurrences per respondent per year (4 process vents routed to control devices/refinery x 2 occurrences/process vent/year).
cc. We assume 2 labor hours per occurrence, and that there will be 6 occurrences per respondent per year (3 heat exchange systems/refinery x 2 occurrences/heat exchange system/year).
dd. These additional semiannual compliance reporting costs are for affected facilities with new requirements added in the 2015 amendments to subpart CC.
ee. The fenceline monitoring reports are submitted quarterly.
ff. We assume sources already have record systems in place to monitor existing operations. The burden shown below reflects reconstructed units affected by the standard.
gg. We assume 12 occurrences per respondent per year and 24 labor hours per occurrence for recordkeeping requirements associated with heat exchange systems. The labor hours are divided equally between technical and plant operators.
hh. We have included the labor associated with recording and transmitting data to develop initial and semiannual reports. We assume it takes respondents approximately 3.5 hours at each of the 12 Group 1storage vessels, 99 hours for equipment leaks at each of the 11 process units, 29 hours at each of the 4 process vents routed to control devices, and 1 hour at each of the 3 heat exchange systems.
ii. These additional recordkeeping costs are for affected facilities with new requirements added in the 2015 amendments.
jj. We assume existing sources will provide initial training to employees associated with new affected facilities, and that there will be periodic refresher trainings. For ‘Maintenance Vents - <72 lb/day’, this requirement is a result of the 2018 amendment.
kk. We assume annual training for heat exchange system requirements will require 2 labor hours per operator, and assume there are 10 operators per facility.
ll. These additional training costs are for affected facilities with new requirements added in the 2015 amendments.
mm. Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
N/A – Not Applicable

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Sheet 2: Table 2

Table 2. Average Annual EPA Burden and Cost -NESHAP for Petroleum Refineries (40 CFR Part 63, Subpart CC) (Renewal)
Activity	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	EPA person-hours per occurrence	No. of occurrences per plant per year	EPA person-hours per plant per year (C=AxB)	Plants per year a	Technical person-hours per year (E=CxD)	Management person-hours per year (Ex0.05)	Clerical person-hours per year (Ex0.1)	Cost b $
1. Initial notifications c										Labor Rates:
Notification of reconstruction – process vents d	1	4	4	14.2	57	3	6	$3,231.04		Management	$68.37
Notification of compliance status – storage vessels e	1	12	12	14.2	170	9	17	$9,693.12		Technical	$50.72
Notification of compliance status – equipment leaks e	1	11	11	14.2	156	8	16	$8,885.36		Clerical	$27.46
Notification of compliance status – process vents e	1	9	9	14.2	128	6	13	$7,269.84
Notification of compliance status – heat exchange systems	2	3	6	14.2	85	4	9	$4,846.56
Notification of performance test – process vent control devices e	1	4	4	14.2	57	3	6	$3,231.04
Notification of storage vessel inspections	1	12	12	14.2	170	9	17	$9,693.12
Notification of compliance status – Storage vessels, delayed cokers f	1	2	2	0	0	0	0	$0
Notification of compliance status – Relief valves, flares f	1	2	2	0	0	0	0	$0
Request for alternative monitoring for fenceline requirements f	1	1	1	0	0	0	0	$0
Flare management plan review g	1	1	1	47	47	2	5	$2,673.57
2. Periodic reports h
Semiannual parameter exceedance reports	4	2	8	142	1136	57	114	$64,620.79
Semiannual compliance - Storage tank seal gap failure reports	4	2	8	142	1136	57	114	$64,620.79
Semiannual compliance – LDAR reports	10	2	20	142	2840	142	284	$161,551.98
Semiannual compliance – Process vents	1	2	2	142	284	14	28	$16,155.20
Semiannual compliance – Heat exchange systems	1	2	2	142	284	14	28	$16,155.20
Semiannual reports – Storage	0.25	0.5	0.125	142	18	1	2	$1,009.70
Semiannual reports – Relief valves	1	2	2	142	284	14	28	$16,155.20
Semiannual reports – Bypass lines	0.25	0.5	0.125	142	18	1	2	$1,009.70
Semiannual reports – Delayed cokers	0.25	0.5	0.125	142	18	1	2	$1,009.70
Semiannual reports – Flares	2	4	8	142	1136	57	114	$64,620.79
Semiannual reports - Maintenance Vents	0.25	0.5	0.125	14.2	2	0	0	$100.97
Quarterly report for fenceline monitoring	1	4	4	142	568	28	57	$32,310.40
Audit Record Review
Maintenance Vents - <72 lb/day i	0.2	1	0.2	36	7.1	0.4	0.7	$403.88
TOTAL (rounded) j					9,890			$373,000
Assumptions:
a. We estimate there are 142 existing petroleum refineries, and that no new refineries will become subject to the rule over the 3-year period of this ICR. We have further assumed that a refinery has the following affected units: 12 Group 1 storage vessels; 11 process units subject to LDAR provisions; 9 process vents for requiring monitoring, recordkeeping, and reporting; and 3 heat exchange systems subject to a monthly sampling program for VOC leak detection and repair, as well as recordkeeping and reporting requirements to ensure compliance with the program.
b. This ICR uses the following labor rates: $68.37 for managerial, $50.72 for technical, and $27.46 for clerical labor. These rates are from the Office of Personnel Management (OPM), 2020 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. Only new respondents or respondents that reconstruct units must comply with initial monitoring, recordkeeping and reporting requirements for existing units, including: initial notifications; the design analysis and establishment of operating parameters for storage vessels, LDAR initial requirements, initial performance testing for process vents routed to a control device; heat exchanger requirements, and development of startup and malfunction plans and record systems for each unit. We estimate that existing refineries will reconstruct 10 percent of their existing units.
d. The notification of reconstruction is only required for process vents routed to control devices. We assume that 4 process vents per refinery are routed to control devices, and of which existing refineries will reconstruct 10 percent.
e. The notification of compliance status includes performance test results, as required by the general provisions.
f. Notification of compliance status is a one-time response required by the 2015 amendment.
g. We assume one-third of all respondents (142/3 = 47) make periodic updates to the Flare Management Plan each year.
h. The rule requires that respondents submit semiannual compliance reports addressing each affected unit subject to the rule.
i. Assumes that 25% of the respondents will be audited over the 3-year period of the ICR.
j. Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
N/A – Not Applicable

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Sheet 3: O&M

Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A) Continuous Monitoring Device	(B) Capital/Startup Cost for One Respondent	(C) Number of New Respondents	(D) Total Capital/Startup Cost, (B X C)	(E) Annual O&M Costs for One Respondent	(F) Number of Respondents with O&M	(G) Total O&M (E x F)
Air stripping column and FID analyzer a, b	$116,870	0	$0	$1,093	142	$155,226
Totals c			$0			$155,000
a. We assume that no new refineries will become subject to this regulation. New refineries will need to purchase and install LDAR equipment for heat exchange systems, including an FID analyzer and a portable air stripping column apparatus, for sample collection. For each refinery, we estimate the total cost to be $116,870, assuming a capital discount rate of 7 percent, annual interest over 10 years, and that there will be no other capital costs associated with other affected units.
b. The O&M cost assumes one mid-point calibration of sampling equipment prior to each sampling event. For each refinery, we assume 0.25 technical labor hours per sampling event, 12 sampling events per refinery per year, and 3 heat exchange systems per refinery.
c. Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
Total Annual Responses							Number of Respondents
(A) Information Collection Activity	(B) Number of Respondents	(C) Number of Responses	(D) Number of Existing Respondents That Keep Records But Do Not Submit Reports	(E) Total Annual Responses E=(BxC)+D				Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
Initial Notifications a:
Notification of reconstruction process vents b	14.2	4	0	56.8				(A)	(B)	(C)	(D)	(E)
Notification of compliance status – storage vessels	14.2	12	0	170.4			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)
Notification of compliance status – equipment leaks	14.2	11	0	156			1	14.2	142	0	14.2	142
Notification of compliance status – process vents	14.2	9	0	128			2	14.2	142	0	14.2	142
Notification of compliance status – heat exchange systems	14.2	3	0	43			3	14.2	142	0	14.2	142
Notification of performance test – process vent control devices b	14.2	4	0	57			Average	14.2	142	0	14.2	142
Notification of storage vessel inspections	14.2	12	0	170			1 New respondents include sources with constructed, reconstructed and modified affected facilities. In this standard, existing respondents who construct new facilities or modify existing facilities submit initial notifications.
Notification of compliance status – Storage vessels, delayed cokers	0	2	0	0
Notification of compliance status – Relief valves, flares	0	2	0	0
Request for alternative monitoring for fenceline requirements	0	1	0	0
Flare management plan review	47	1	0	47
Periodic Reports:
Semiannual parameter exceedance reports	142	2	0	284
Semiannual compliance reports - Storage tank seal gap failure	142	2	0	284
Semiannual compliance reports – LDAR	142	2	0	284
Semiannual compliance reports – process vents	142	2	0	284
Semiannual compliance reports – heat exchange system	142	2	0	284
Semiannual reports – Storage d	142	0.5	0	71
Semiannual reports – Relief valves d	142	2	0	284
Semiannual reports – Bypass lines d	142	0.5	0	71
Semiannual reports – Delayed cokers d	142	0.5	0	71
Semiannual reports – Flares d	142	4	0	568
Semiannual reports - Maintenance Vents d, e	14.2	0.5	0	7
Quarterly report for fenceline monitoring	142	4	0	568
Maintenance vents <72lb/day f	36	1	0	36
TOTAL				3,924
a Only new respondents or respondents with reconstructed units must comply with initial monitoring, recordkeeping, and reporting requirements for existing units, including initial notifications; design analysis and establishment of operating parameters for storage vessels; LDAR initial requirements; initial performance testing for process vents routed to a control device; heat exchanger requirements; and development of startup and malfunction plans and record systems for each unit. We estimate that existing refineries will reconstruct 10 percent of their existing units.
b We assume that 4 process vents per refinery are routed to control devices, and that existing refineries will reconstruct 10 percent of these vents.
c Assume that one-third of refineries revise their flare management plan each year and submit the revised version to EPA for review.
d These additional semiannual reports were added in the 2015 amendments.
e Semiannual reports for maintenance vents are expected for 10% of the reporters during each year.
f Assumes that 25% of the respondents will be audited over the 3-year period of the ICR. This requirement is a result of the 2018 amendments, and is documented in Table 1 of the Supporting Statement for ICR 1692.12.
Estimating Capital and Operation and Maintenance Costs for the 2015 Amendments
Capital vs. Operation and Maintenance (O&M) Costs for Fenceline Monitoring
(A) Facility Size (acreage)	(B) Capital Cost for One Affected Facility	(C) Number of Affected Facilities	(D) Total Capital Cost (B x C)	(E) Number of Affected Facilities	(F) Annual O&M Costs for One Affected Facility a	(G) Total Annual O&M Cost (E x F)
Small	$86,650	0	$0	84	$8,665	$727,860
Medium	$89,270	0	$0	27	$8,927	$241,029
Large	$90,880	0	$0	31	$9,088	$281,728
TOTAL		0	$0	142		$1,250,000
a For fenceline monitoring, costs vary depending on the physical size (not capacity) of the refinery where a small refinery is less than 750 acres, a medium refinery is between 750 acres and 1,500 acres, and a large refinery is greater than 1,500 acres. There are 84 small refineries, 27 medium refineries and 31 large refineries, for a total of 142 refineries. There are no affected facilities with capital costs, as all fenceline monitoring equipment required by the 2015 amendment have has been installed.
b Assumed to be 10 percent of capital cost. EPA assumes that all refineries will use in-house labor to collect samples and would conduct sample analysis in-house.
Note: Totals have been rounded to three significant figures.
Capital vs. Operation and Maintenance (O&M) Costs for Flare Monitoring
(A) Monitoring Equipment or Material	(B) Capital Cost for One Affected Flare	(C) Number of Affected Flares	(D) Total Capital Cost (B x C)	(E) Annual O&M Costs for One Affected Flare	(F) Number of Affected Flares	(G) Total Annual O&M Cost (E x F)
Calorimeter	$105,000	0	$0	$20,100	85	$1,708,500
H2 Analyzer	$36,000	0	$0	$20,000	243	$4,860,000
Steam Controls/Flow Monitor	$684,000	0	$0	$59,730	190	$11,348,700
Air Controls/ Flow Monitor	$164,000	0	$0	$36,520	37	$1,351,240
Average Natural Gas (NG) Costs per Flare to Meet NHVcz Targets	$0	0	$0	$100,030	190	$19,005,700
Steam Costs (Savings) per Flare for Steam Controls to Meet NHVcz Targets	$0	0	$0	($56,470)	190	($10,729,300)
Engineering Calculation Costs	$7,000	0	$0	$12,500	267	$3,337,500
TOTAL		0	$0		510	$30,900,000
a There are 510 flares that would be subject to the flare monitoring requirements at the 142 major source refineries. There are no affected facilities with capital costs, as all flare monitoring equipment required by the 2015 amendment has been installed. If a source reconstructs or modifies a flare, EPA assumes the equipment will be re-used.									$155,000
b Note: Totals have been rounded to three significant figures.									$1,250,000
									$30,900,000
Capital vs. Operation and Maintenance (O&M) Costs for Relief Valves									$323,000
(A) Equipment or Material	(B) Capital Cost for One Affected Valve	(C) Number of Affected Valves	(D) Total Capital Cost (A x B)	(E) Annual O&M Costs for One Affected Valve	(F) Number of Affected Valves	(G) Total Annual O&M Cost (D x B)			$32,628,000	Total O&M Costs
Install Monitor on Relief Valves	$809	0	$0	$81	1,600	$129,429
Relief Valves Requiring Additional Prevention Measures	$1,208	0	$0	$121	1,600	$193,333
TOTAL		0	$0		3,200	$323,000
a Capital costs are based on the 2015 final rule ICR, which assumed the total capital cost to install a monitor on each relief valve is $3,882,880 for an estimated 4,800 relief valves over the next 3 years ($3,882,880/4800 valves = $809/valve). Additionally, it was estimated that the cost for relief valves requiring additional prevention measures would be $5,800,000 ($1,208/valve). This ICR assumes no capital costs, as all monitoring equipment required by the 2015 amendment have been installed and there are no new petroleum refineries.