Burden Calculation Tables

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Overview

Summary
Table 1
Table 2
Capital O&M
Responses
Respondents

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Sheet 1: Summary

ICR Summary Information
Hours per Response	38
Number of Respondents	130
Total Estimated Burden Hours	16,100
Total Estimated Costs	$10,000,000
Annualized Capital O&M	$8,020,000
Total Annual Responses	426

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Sheet 2: 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)
					123.94	157.61	62.52
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	92	106	-	-
2. Survey and Studies	N/A									CRU	104	138	-	-
3. Reporting Requirements										SRU	96	231	25	60
A. Familiarize with rule requirements c	2	1	2	130	260	13.00	26.00	$35,899
B. Required activities											Total	475
Initial Performance test d,e	40	1	40	0	0	0	0	$0
PM Performance Test (internal)f	40	1	40	45.9	1837.33	91.87	183.73	$253,685			Note: We estimate that there are 130 refineries (major sources) with 475 units. This includes 92 sources with 106 FCCU units, 104 sources with 138 CRU units, and 96 sources with 231 SRU units. Of sources with SRU units, we assume 25 sources are using CEMS on 60 units.
HCN Performance Test (internal) d,e,g	40	1	40	0	0.0	0.0	0.0	$0
Operating, maintenance, and monitoring plan d	40	1	40	0	0	0	0	$0
RATA for units using CEMs h	40	1	40	60	2406	120	241	$332,237
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
Notification of PM performance test f	2	1	2	45.9	92	5	9	$12,684
Notification of HCN performance test g	2	1	2	0	0	0	0	$0
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 i	10	2	20	130	2600	130	260	$358,989
Subtotal for Reporting Requirements					8,275			$993,494
4. Recordkeeping Requirements
A. Familiarize with rule requirements	See 3A
B. Plan activities	See 3B
C. Implement activities	See 3B
D. Develop record system j	N/A
E. Time to enter information k, l
Records of operations m	1	52	52	130	6760	338	676	$933,370
F. Time to train personnel d, n	4	1	4	0	0	0	0	$0
G. Time to adjust existing ways to comply with previously applicable requirements	N/A					0
H. Time to transmit or disclose information m	0.25	1	0.25	130	32.5	1.63	3.25	$3,459
I. Time for audits	N/A
Subtotal for Recordkeeping Requirements					7,811			$936,829
TOTAL LABOR BURDEN AND COST (rounded)o					16,100			$1,930,000		37.8	hr/response
TOTAL CAPITAL AND O&M COSTS (rounded)o								$8,020,000
GRAND TOTAL (rounded)o								$10,000,000
Assumptions:
a We have determined that 130 major petroleum refineries will have one or more affected facilities subject to the standard. This includes 92 sources with 106 FCCU. No new or reconstructed facilities are expected over the next 3 years.
b This ICR uses the following labor rates: Managerial $157.61 ($75.05 + 110%); Technical $123.94 ($59.02 + 110%); and Clerical $62.52 ($29.77 + 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 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 varying industry wage rates and the additional overhead business costs of employing workers beyond their wages and benefits, including business expenses associated with hiring, training, and equipping their employees.
c Assumed 130 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 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 106 FCCUs that will test over the 3 years so each year, approximately 45.9 performance tests will be conducted (106 units / 3 years + 106 × 0.1 = 45.9 tests/year.
g 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.
h 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 96 respondents with 231 SRU units (2.41 units/respondent). There are 25 respondents with SRUs using CEMs. Therefore, the number of SRUs using CEMs is 25 x 2.4 = 60 (rounded).
i We have assumed that all sources would be submitting semiannual compliance reports.
j We have assumed that these sources will have the record system in place to monitor operations.
k 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.
l We have assumed that all respondents would have to keep records of their operations according to the operation and maintenance plan.
m 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.
n 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.
o Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: 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)
					52.37	70.56	28.34
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	92	106
Notification of construction/reconstruction	N/A									CRU	104	138
Notification of actual startup	N/A									SRU	96	231
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	45.9	91.87	4.59	9.19	$5,395.51
Notification of HCN performance test d	2	1	2	0	0	0	0	$0
Notification of compliance status b	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 repeat performance test report	8	1	8	0	0	0	0	$0
Review of RATA for CEMS e	8	1	8	60	480	24	48	$28,191.36
Review of compliance report	N/A
Review of semiannual compliance reports f	2	2	4	130	520	26	52	$30,540.64
Review of NESHAP waiver application	4	1	4	0	0	0	0	$0
TOTAL ANNUAL BURDEN AND COST (rounded)g					1,260			$64,100
Assumptions:
a This cost is based on the following labor rates: Managerial rate of $70.56 (GS-13, Step 5, $44.10 +60%), Technical rate of $52.37 (GS-12, Step 1, $32.73 + 60%), and Clerical rate of $28.34 (GS-6, Step 3, $17.71 + 60%). These rates are from the Office of Personnel Management (OPM), 2022 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.
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 106 FCCUs that will test over the 3 years so each year, approximately 45.9 performance tests will be conducted (106 units / 3 years + 106 × 0.1 = 45.9 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 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 96 respondents with 231 SRU units (2.41 units/respondent). There are 25 respondents with SRUs using CEMs. Therefore, the number of SRUs using CEMs is 25 x 2.4 = 60 (rounded).
f We have assumed that all sources would be submitting semiannual compliance reports.
g Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 4: Capital 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, (E X F)
COMS (FCCUs) a	$95,700	0	$0	$28,600	23	$657,800
CPMS (FCCUs) b	$18,900	0	$0	$25,350	69	$1,749,150
CPMS (CRUs) c	$0	0	$0	$17,940	138	$2,475,720
CPMS (SRUs) d	$74,000	0	$0	$26,000	71	$1,846,000
CEMS (SRUs) e	$150,000	0	$0	$34,840	25	$871,000
PM Performance Test (outsourced) f	$0	0	$0	$9,200	45.9	$422,280
HCN Performance Test (outsourced) g	$0	0	$0	$10,000	0	$0
Totals (rounded) h			$0			$8,020,000		$8,020,000
a COMS - continuous opacity monitoring system. We assume 25% of the 92 sources with FCCUs are using COMS (0.25 * 92 = 23).
b CPMS - continuous parametric monitoring system. We assume the other 75% of the 92 sources with FCCUs are using CMPS (0.75 * 92 = 69).
c We estimate that there are 138 CRUs using CPMS for monitoring, with an O&M cost of $17,940 per CPMS.
d We assume 74% of the 96 sources with SRUs are using CPMS (.74 * 96 = 71).
e CEMS – continuous emission monitoring system. We assume 25 sources with SRU units are using CEMS on 60 units.
f 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 45.9 units per year will need to have a PM performance test (106 units/3 years + 106 × 0.1 = 45.9). We assume it costs $9,200 per unit to conduct a EPA Method 5 performance test.
g 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.
h Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 5: 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 a,c	45.9	1.15	0	52.79
Notification of HCN performance test b,c	0	1.15	0	0
Particulate matter performance test reports a,c	45.9	1.15	0	52.79
HCN performance test reports b,c	0	1.15	0	0
Notification of performance test d	0	1	0	0
Semiannual compliance report	130	2	0	260
Relative accuracy test audits for units using CEMs e	25	2.41	0	60
			Total	426
a 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 106 FCCUs that will test over the 3 years so each year, approximately 45.9 performance tests will be conducted (106 units / 3 years + 106 × 0.1 = 45.9 tests/year.
b 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.
c There are approximately 106 catalytic cracking units at 92 facilities, so each facility would report 1.15 responses per year, i.e., 106 units / 92 facilities = 1.15 responses/facility.
d We have assumed that this activity is a one-time activity that applies only to new sources.
e There are approximately 231 SRU at 96 facilities, so each facility would report 2.41 responses per year, i.e., 231 units / 96 facilities = 2.41 responses/facility. We assume 25 sources with SRU units are using CEMS.

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Sheet 6: Respondents

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	0	130	0	0	130
2	0	130	0	0	130
3	0	130	0	0	130
Average	0	130	0	0	130
a New respondents include sources with constructed and reconstructed affected facilities.