Burden Calculation Tables

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Overview

Cover
Table 1
Table 2
Table 3
Table 4
Table 5
Table 6
Table 7
Table 8
Capital O&M
Responses
Respondents

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Sheet 1: Cover

ATTACHMENT 1

SUPPORTING STATEMENT

Review of the New Source Performance Standards for VOC from Distillation Operations in the SOCMI (40 CFR Part 60, Subpart NNNa) (Proposed Rule)

TABLES 1, 2, and 3

Annual Respondent Burden and Cost of the Review of the New Source Performance Standards for VOC from Distillation Operations in the SOCMI (40 CFR Part 60, Subpart NNNa) (Proposed Rule) – Years 1-3

TABLE 4

Summary of Annual Respondent Burden and Cost of the Review of the New Source Performance Standards for VOC from Distillation Operations in the SOCMI (40 CFR Part 60, Subpart NNNa) (Proposed Rule)

TABLES 5, 6, and 7

Annual Agency Burden and Cost of the Review of the New Source Performance Standards for VOC from Distillation Operations in the SOCMI (40 CFR Part 60, Subpart NNNa) (Proposed Rule) – Years 1-3

TABLE 8

Summary of Annual Agency Burden and Cost of the Review of the New Source Performance Standards for VOC from Distillation Operations in the SOCMI (40 CFR Part 60, Subpart NNNa) (Proposed Rule)

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Sheet 2: Table 1

Table 1: Annual Respondent Burden and Cost - Review of the New Source Performance Standards for VOC from Distillation Operations in the SOCMI (40 CFR Part 60, Subpart NNNa) (Proposed Rule)
					$101.24	$161.34	$45.17
Burden item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Person-hours per occurrence	No. of occurrences per respondent per year	Person-hours per respondent per year (C=AxB)	Respondents per year a	Technical hours per year (E=CxD)	Management hours per year (F=Ex0.05)	Clerical hours per year (G=Ex0.1)	Total cost per year ($) b
1. Applications	N/A
2. Survey and Studies	N/A
3. Reporting requirements
A. Familiarize with regulatory requirements c
New Sources	8	1	1	2.3	2	0.12	0.23	$265.59
Existing Sources	1	1	1	0	0	0	0	$0.00
B. Required activities
Initial performance test report	60	1	60	2.3	140	7	14	$15,935.36
Repeat performance test report d	60	1	60	0.47	28	1.4	2.8	$3,187.07
C. Write report
Notification of construction/modification	2	1	2	2.3	4.67	0.23	0.47	$531.18
Notification of actual startup	1	1	1	2.3	2.33	0.12	0.23	$265.59
Notification of initial/repeat performance test	2	1	2	2.8	5.6	0.3	0.6	$637.41
Semiannual report	3	2	6	2.3	14	1	1	$1,593.54
Subtotal for Reporting Requirements					226			$22,416
4. Recordkeeping requirements
Records of operating parameters for control devices	1	12	12	2.3	28	1.4	2.8	$3,187.07
Records of operating conditions exceeding last performance test	1	8	8	2.3	18.67	1	2	$2,124.71
Records of flow events from a relief valve discharge e	1	1	1	0	0	0	0	$0.00
Records for bypass lines e	1	1	1	0	0	0	0	$0.00
Subtotal for Recordkeeping Requirements					54			$5,312
TOTAL LABOR BURDEN AND COST (rounded) f					280			$27,700
TOTAL CAPITAL AND O&M COST (rounded) f								$3,710,000
GRAND TOTAL (rounded) f								$3,740,000
Assumptions:
a We have assumed that there will be 7 new respondents over the three-year period of this ICR. We have assumed that on average, there will be 2.3 new respondents per year.
b This ICR uses the following labor rates for privately-owned sources: $161.34 for managerial, $101.24 for technical, and $45.17 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, May 2021, National Industry-Specific Occupational Employment and Wage Estimates for NAICS 325000 - Chemical Manufacturing. These rates have been adjusted using a Fringe Benefit Loading Rate of 1.5 and an Overhead and Profit Rate of 1.4 (Mean Hourly Rate * Fringe Benefit Loading Rate * Overhead and Profit Rate = Loaded Rate) 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 This ICR assumes all existing respondents will have to familiarize with the regulatory requirements each year.
d Assume 20 percent of initial performance tests must be repeated due to failure.
e We have assumed that no respondents will bypass the control device or have a relief valve discharge to the atmosphere during the three-year period of this ICR.
f 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: Annual Respondent Burden and Cost - Review of the New Source Performance Standards for VOC from Distillation Operations in the SOCMI (40 CFR Part 60, Subpart NNNa) (Proposed Rule)
					$101.24	$161.34	$45.17
Burden item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Person-hours per occurrence	No. of occurrences per respondent per year	Person-hours per respondent per year (C=AxB)	Respondents per year a	Technical hours per year (E=CxD)	Management hours per year (F=Ex0.05)	Clerical hours per year (G=Ex0.1)	Total cost per year ($) b
1. Applications	N/A
2. Survey and Studies	N/A
3. Reporting requirements
A. Familiarize with regulatory requirements c
New Sources	8	1	1	2.3	2	0.12	0.23	$265.59
Existing Sources	1	1	1	2.3	2	0.12	0.23	$265.59
B. Required activities
Initial performance test report	60	1	60	2	140	7	14	$15,935.36
Repeat performance test report d	60	1	60	0.47	28	1.4	2.8	$3,187.07
C. Write report
Notification of construction/modification	2	1	2	2	5	0.23	0.47	$531.18
Notification of actual startup	1	1	1	2	2	0.12	0.23	$265.59
Notification of initial/repeat performance test	2	1	2	2.80	5.6	0.3	0.6	$637.41
Semiannual report	3	2	6	5	28	1	3	$3,187.07
Subtotal for Reporting Requirements					245			$24,275
4. Recordkeeping requirements
Records of operating parameters for control devices	1	12	12	2	28	1.4	2.8	$3,187.07
Records of operating conditions exceeding last performance test	1	8	8	5	37	2	4	$4,249.43
Records of flow events from a relief valve discharge e	1	1	1	0	0	0	0	$0.00
Records for bypass lines e	1	1	1	0	0	0	0	$0.00
Subtotal for Recordkeeping Requirements					75			$7,437
TOTAL LABOR BURDEN AND COST (rounded) f					320			$31,700
TOTAL CAPITAL AND O&M COST (rounded) f								$4,430,000
GRAND TOTAL (rounded) f								$4,460,000
Assumptions:
a We have assumed that there will be 7 new respondents over the three-year period of this ICR. We have assumed that on average, there will be 2.3 new respondents per year.
b This ICR uses the following labor rates for privately-owned sources: $161.34 for managerial, $101.24 for technical, and $45.17 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, May 2021, National Industry-Specific Occupational Employment and Wage Estimates for NAICS 325000 - Chemical Manufacturing. These rates have been adjusted using a Fringe Benefit Loading Rate of 1.5 and an Overhead and Profit Rate of 1.4 (Mean Hourly Rate * Fringe Benefit Loading Rate * Overhead and Profit Rate = Loaded Rate) 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 This ICR assumes all existing respondents will have to familiarize with the regulatory requirements each year.
d Assume 20 percent of initial performance tests must be repeated due to failure.
e We have assumed that no respondents will bypass the control device or have a relief valve discharge to the atmosphere during the three-year period of this ICR.
f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 4: Table 3

Table 3: Annual Respondent Burden and Cost - Review of the New Source Performance Standards for VOC from Distillation Operations in the SOCMI (40 CFR Part 60, Subpart NNNa) (Proposed Rule)
					$101.24	$161.34	$45.17
Burden item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Person-hours per occurrence	No. of occurrences per respondent per year	Person-hours per respondent per year (C=AxB)	Respondents per year a	Technical hours per year (E=CxD)	Management hours per year (F=Ex0.05)	Clerical hours per year (G=Ex0.1)	Total cost per year ($) b
1. Applications	N/A
2. Survey and Studies	N/A
3. Reporting requirements
A. Familiarize with regulatory requirements c
New Sources	8	1	1	2.3	2.33	0.12	0.23	$265.59
Existing Sources	1	1	1	4.7	4.67	0.23	0.47	$531.18
B. Required activities
Initial performance test report	60	1	60	2.33	140	7	14	$15,935.36
Repeat performance test report d	60	1	60	0.47	28	1.4	2.8	$3,187.07
C. Write report
Notification of construction/modification	2	1	2	2.33	4.67	0.23	0.47	$531.18
Notification of actual startup	1	1	1	2.33	2.33	0.12	0.23	$265.59
Notification of initial/repeat performance test	2	1	2	2.80	5.6	0.3	0.6	$637.41
Semiannual report	3	2	6	7	42	2	4	$4,780.61
Subtotal for Reporting Requirements					264			$26,134
4. Recordkeeping requirements
Records of operating parameters for control devices	1	12	12	2.33	28	1.4	2.8	$3,187.07
Records of operating conditions exceeding last performance test	1	8	8	7	56	3	6	$6,374.14
Records of flow events from a relief valve discharge e	1	1	1	0	0	0	0	$0.00
Records for bypass lines e	1	1	1	0	0	0	0	$0.00
Subtotal for Recordkeeping Requirements					97			$9,561
TOTAL LABOR BURDEN AND COST (rounded) f					361			$35,700
TOTAL CAPITAL AND O&M COST (rounded) f								$5,140,000
GRAND TOTAL (rounded) f								$5,180,000
Assumptions:
a We have assumed that there will be 7 new respondents over the three-year period of this ICR. We have assumed that on average, there will be 2.3 new respondents per year.
b This ICR uses the following labor rates for privately-owned sources: $161.34 for managerial, $101.24 for technical, and $45.17 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, May 2021, National Industry-Specific Occupational Employment and Wage Estimates for NAICS 325000 - Chemical Manufacturing. These rates have been adjusted using a Fringe Benefit Loading Rate of 1.5 and an Overhead and Profit Rate of 1.4 (Mean Hourly Rate * Fringe Benefit Loading Rate * Overhead and Profit Rate = Loaded Rate) 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 This ICR assumes all existing respondents will have to familiarize with the regulatory requirements each year.
d Assume 20 percent of initial performance tests must be repeated due to failure.
e We have assumed that no respondents will bypass the control device or have a relief valve discharge to the atmosphere during the three-year period of this ICR.
f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 5: Table 4

Table 4 - Summary of Annual Respondent Burden and Cost - Review of the New Source Performance Standards for VOC from Distillation Operations in the SOCMI (40 CFR Part 60, Subpart NNNa) (Proposed Rule)
Year	Total Labor Hours	Labor Costs	Non-Labor (Capital/Startup and O&M) Costs	Total Costs
1	280	$27,700	$3,710,000	$3,737,700
2	320	$31,700	$4,430,000	$4,461,700
3	361	$35,700	$5,140,000	$5,175,700
Total (rounded)	961	$95,100	$13,300,000	$13,400,000
Average (rounded)	320	$31,700	$4,430,000	$4,460,000

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Sheet 6: Table 5

Table 5: Average Annual EPA Burden and Cost Year One - Review of the New Source Performance Standards for VOC from Distillation Operations in the SOCMI (40 CFR Part 60, Subpart NNNa) (Proposed Rule)
					$51.23	$69.04	$27.73
Burden item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Person-hours per occurrence	No. of occurrences per respondent per year	Person-hours per respondent per year (C=AxB)	Respondents per year a	Technical hours per year (E=CxD)	Management hours per year (F=Ex0.05)	Clerical hours per year (G=Ex0.1)	Total cost per year ($) b
Report review: New plant
Notification of construction/ modification	2	1	2	2.3	4.67	0.23	0.47	$268.12
Notification of actual startup	2	1	2	2.3	4.67	0.23	0.47	$268.12
Notification of initial/repeat performance test	2	1	2	2.8	5.60	0.28	0.56	$321.75
Initial performance test	8	1	8	2.3	18.7	0.93	1.87	$1,072.49
Repeat performance test c	8	1	8	0.5	3.73	0.19	0.37	$214.50
Semiannual report	2	2	4	2.3	9.33	0.47	0.93	$536.25
TOTAL (rounded) d					54			$2,680
Assumptions:
a We have assumed that there will be 7 new respondents over the three-year period of this ICR. We have assumed that on average, there will be 2.3 new respondents per year.
b This ICR uses the following labor rates: $69.04 for managerial, $51.23 for technical, and $27.73 for clerical labor. 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 Assume 20 percent of initial performance tests must be repeated due to failure.
d Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 7: Table 6

Table 6: Average Annual EPA Burden and Cost Year Two - Review of the New Source Performance Standards for VOC from Distillation Operations in the SOCMI (40 CFR Part 60, Subpart NNNa) (Proposed Rule)
					$51.23	$69.04	$27.73
Burden item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Person-hours per occurrence	No. of occurrences per respondent per year	Person-hours per respondent per year (C=AxB)	Respondents per year a	Technical hours per year (E=CxD)	Management hours per year (F=Ex0.05)	Clerical hours per year (G=Ex0.1)	Total cost per year ($) b
Report review: New plant
Notification of construction/ modification	2	1	2	2.3	4.67	0.23	0.47	$268.12
Notification of actual startup	2	1	2	2.3	4.67	0.23	0.47	$268.12
Notification of initial/repeat performance test	2	1	2	2.8	5.60	0.28	0.56	$321.75
Initial performance test	8	1	8	2.3	18.7	0.93	1.87	$1,072.49
Repeat performance test c	8	1	8	0.5	3.73	0.19	0.37	$214.50
Semiannual report	2	2	4	4.7	18.67	0.93	1.87	$1,072.49
TOTAL (rounded) d					64			$3,220
Assumptions:
a We have assumed that there will be 7 new respondents over the three-year period of this ICR. We have assumed that on average, there will be 2.3 new respondents per year.
b This ICR uses the following labor rates: $69.04 for managerial, $51.23 for technical, and $27.73 for clerical labor. 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 Assume 20 percent of initial performance tests must be repeated due to failure.
d Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 8: Table 7

Table 7: Average Annual EPA Burden and Cost Year Three - Review of the New Source Performance Standards for VOC from Distillation Operations in the SOCMI (40 CFR Part 60, Subpart NNNa) (Proposed Rule)
					$51.23	$69.04	$27.73
Burden item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Person-hours per occurrence	No. of occurrences per respondent per year	Person-hours per respondent per year (C=AxB)	Respondents per year a	Technical hours per year (E=CxD)	Management hours per year (F=Ex0.05)	Clerical hours per year (G=Ex0.1)	Total cost per year ($) b
Report review: New plant
Notification of construction/ modification	2	1	2	2.3	4.67	0.23	0.47	$268.12
Notification of actual startup	2	1	2	2.3	4.67	0.23	0.47	$268.12
Notification of initial/repeat performance test	2	1	2	2.8	5.60	0.28	0.56	$321.75
Initial performance test	8	1	8	2.3	18.7	0.93	1.87	$1,072.49
Repeat performance test c	8	1	8	0.5	3.73	0.19	0.37	$214.50
Semiannual report	2	2	4	7.0	28.00	1.40	2.80	$1,608.74
TOTAL (rounded) d					75			$3,750
Assumptions:
a We have assumed that there will be 7 new respondents over the three-year period of this ICR. We have assumed that on average, there will be 2.3 new respondents per year.
b This ICR uses the following labor rates: $69.04 for managerial, $51.23 for technical, and $27.73 for clerical labor. 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 Assume 20 percent of initial performance tests must be repeated due to failure.
d Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 9: Table 8

Table 8: Summary of Average Annual EPA Burden and Cost - Review of the New Source Performance Standards for VOC from Distillation Operations in the SOCMI (40 CFR Part 60, Subpart NNNa) (Proposed Rule)
Year	Total Hours	Labor Costs	Non-Labor Costs	Total Costs
1	54	$2,680	$0	$2,680
2	64	$3,220	$0	$3,220
3	75	$3,750	$0	$3,750
Total (Rounded)	193	$9,650	$0	$9,650
Average (Rounded)	64	$3,220	$0	$3,220

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Sheet 10: Capital O&M

Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A)	(B)	(C)	(D)	(E)	(F)	(G)
Continuous Monitoring Device a	Capital/Startup Cost for One Respondent	Number of New Respondents a, b	Total Capital/Startup Cost, (B X C) a	Annual O&M Costs for One Respondent	Number of Respondents with O&M a, b	Total O&M, (E X F) a
Flare monitoring requirements	$3,752,223	0.74	$2,764,796	$789,173	2.21	$1,744,487
Maintenance vent requirements	N/A	N/A	N/A	$455	6.63	$3,019
Non-flare control of vent streams	$39,277	0.86	$33,764	$98,429	2.58	$253,844
Carbon cannisters	$26,500	0.25	$6,509	$2,500	0.74	$1,842
H2 Analyzer	$46,274	0.12	$5,683	$29,581	0.37	$10,898
Calorimeter	$134,967	0.12	$16,575	$37,115	0.37	$13,674
Flare Gas Flow Monitor	$565,578	0.12	$69,457	$97,733	0.37	$36,007
Steam Controls/Flow Monitor	$879,215	0.12	$107,974	$150,221	0.37	$55,345
Avg. NG Cost per Flare to Meet NHVcz	$0	0.12	$0	$110,031	0.37	$40,538
Steam Cost Savings per Flare to Meet NHVcz	$0	0.12	$0	-$62,117.19	0.37	-$22,885.28
Total c			$3,000,000			$2,140,000
a Costs are shown in 2021 $. Respondent counts and monitoring and control requirements are based on the memorandum from Eastern Research Group, Inc. to EPA titled "CAA 111(b)(1)(B) review for the SOCMI air oxidation unit processes, distillation operations, and reactor processes NSPS subparts III, NNN, and RRR," March 2023, EPA-HQ-OAR-2022-0730.
b Number of respondents is based on 19 new sources becoming subject to 40 CFR Part 60, Subparts IIIa, NNNa, or RRRa during the three-year period of this ICR. We have assumed that 7 of the 19 will be subject to Subpart NNNa and have adjusted the respondent counts for capital/startup costs by a factor of approximately 0.1228 (2.333/19 = 0.1211) to apportion the capital and O&M estimates for sources subject to NNNa (approximately 2.333 new sources per year for the three-year period of this ICR). We have adjusted the annual O&M costs by a factor of approximately 0.3684 (7/19 = 0.3684) to apportion the costs to the 7 sources that will be subject to Subpart NNNa. The burden and costs for Subparts IIIa and RRRa are accounted for separately under EPA ICR Numbers 2756.01 and 2759.01.
c Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 11: Responses

Summary of Total Annual Responses
(A)	(B)	(C)	(D)	(E)
Information Collection Activity	Number of Respondents 1	Number of Responses	Number of Existing Respondents That Keep Records But Do Not Submit Reports	Total Annual Responses E=(BxC)+D
Initial performance test report	2.3	1	0	2.3
Repeat performance test report	0.5	1	0	0.5
Notification of construction/modification	2.3	1	0	2.3
Notification of actual startup	2.3	1	0	2.3
Notification of initial/repeat performance test	2.8	1	0	2.8
Semiannual report	4.7	2	0	9.3
			Total (rounded)	20
1 Assumes no existing respondents and a total of 7 new respondents will become subject to the standard during the three-year period of this ICR, 2.3 new respondents per year. Assumes 2.3 new respondents per year will submit initial notifications and initial test reports and an overall average of 4.7 respondents per year will submit semiannual reports.

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Sheet 12: 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 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	2.3	0	0	0	2.3
2	2.3	2.3	0	0	4.7
3	2.3	4.7	0	0	7.0
Average	2.3	2.3			4.7
1 New respondents include sources with constructed, reconstructed and modified affected facilities. We have assumed that there will be 7 new respondents over the three-year period of this ICR. We have assumed that on average, there will be 2.3 new respondents per year.