SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY NESHAP for Petroleum Refineries, Catalytic Cracking, Reforming and Sulfur Units
1. Identification of the Information Collection 1(a) Title of the Information Collection NESHAP for Petroleum Refiner ies, Cataly tic Cracking, Reforming and Sulfur Units (40 CFR p art 63, s ubpart UUU) (Renewal) 1(b) Short Characterization/Abstract The National Emission Standards for Hazardous Air Pollutants (NESHAP), for the regulations published at 40 CFR part 63, subp art UUU, were proposed on September 11, 1998, promulgated on April 11, 2002, and amended on February 9, 2005. These regulations apply to three ty pes of affected sources at major source petroleum refineries. The three affected sources are: the fluid catal yt ic cracking unit cataly st regeneration; the cataly tic reforming unit cataly st regeneration; and the sulfur recovery unit. The rule also includes requirements for by

- pass lines associated with the three affected sources. New facilities include those tha t commenced construction or reconstruction after the date of proposal. This information is being collected to assure compliance with 40 CFR part 63, subpart UUU. The rule provides a wide variety of compliance and monitoring options. Depending on the aff ected source and compliance option, the rule may require a continuous opacity monitoring sy stem, a continuous emission monitoring sy stem, a continuous parameter monitoring sy stem, manual inspections, and/or calculations. Continuous opacity monitoring sy st ems and continuous emission monitoring sy stems are in

- place at a majority of facilities due to requirements of the new source performance standards (NSPS for Petroleum Refineries (40 CFR part 60, subpart J).
Ingeneral, all NESHAP standards require initia l notifications, performance tests, and periodic reports by

the owners/operators of the affected facilities. They are also required to maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an affected facility , or any period during which the monitoring sy stem is inoperative. These notifications, reports, and records are essential in determining compliance, and are required of all affected facilities subject to NESHAP. Any owner/operator subject to the provisions of this part shall maintain a file of these measurements, and retain the file for at least five y ears following the date of such measurements, maintenance reports, and records. All reports are sent to the delegated state or local authority

. In the event that there is no such delegated authority , the reports are sent directly to the United States Environmental Protection Agency (EPA) regional office. Based on our consultations with industry representatives, we have determined that o f the2

16 4 existing major source petroleum refineries in the U.S. and its territories, of which 132 of these operate at least one of the affected sources subject to this rule. Furthermore, we have estimated that there is an average of 486 affected units at the 132 major source petroleum refineries. No new or reconstructed facilities are expected over the next 3 y ears. However, it is estimated that three affected emission source units had qualified for a compliance date extension and would be complying with the in itial compliance requirements during the period of this I CR (one per y ear) and one affected facility (0.33 per y ear) will conduct a performance test due to a process/operating change. The 132 respondents to this I CR are publicly owned and operated by petr oleum refineries. None of the facilities are owned by either state, local and tribal agencies or the Federal Government. The burden to the “Affected Public” (i.e., major source petroleum refineries) can be found in Table 1; Annual Respondent Burden and Cost: NESHAP for Petroleum Refineries, Cataly tic Cracking, Reforming and Sulfur Units (40 CFR part 63, subpart UUU). The burden to the “Federal Government” is attributed entirely to work performed by

federal employ ees or government contractors. The burde n to the Federal Government can be found in Table 2: Annual Burden and Cost to the Federal/State Government: NESHAP for Petroleum Refineries, Cataly tic Cracking, Reforming and Sulfur Units (40 CFR part 63, subpart UUU). The Office of Management and Budg et (OMB) approved the currently active I CR without any “ Terms of Clearance. ”
2. Need for and Use of the Collection 2(a) Need/Authority for the Collection The EPA is charged under Section 112 of the Clean Air Act, as amended, to establish standards of performance for each category or subcategory

of major sources and area sources of hazardous air pollutants. These standards are applicable to new or existing sources of hazardous air pollutants and shall require the maximum degree of emission reduction. Inaddition, section 114(a) states that the Administrator may require any

owner/operator subject to any requirement of this Act to: (A) Establish and maintain such records; (B) make such reports;

(C) install, use, and maintain such monitoring equipment, and use such audit procedures, or methods; (D) sample such emissions (in accordance with such procedures or methods, at such locations, at such intervals, during such periods, and in such manner as the Administrator shall prescribe); (E) keep records on c ontrol equipment parameters, production variables or other indirect data when direct monitoring of emissions is impractical; (F) submit compliance certifications in accordance with Section 114(a)(3); and (G) provide such other information as the Administrator may reasonably

require.3

Inthe Administrator's judgment , metal hazardous air pollutants (HAP) and organic HAP emissions from cataly

tic cracking units; organic and inorganic HAP emissions from cataly tic reforming units; and HAP emissions from sulfur re covery units and by

pass lines, cause or contribute to air pollution that may reasonably

be anticipated to endanger public health or welfare. Therefore, the NESHAP were promulgated for this source category at 40 CFR part 63, subpart UUU. 2(b) Practical U tility/Users of the Data The recordkeeping and reporting requirements in the standards ensure compliance with the applicable regulations which where promulgated in accordance with the Clean Air Act. The collected information is also used for targeting in spections and as evidence in legal proceedings. Performance tests are required in order to determine an affected facility ’s initial capability to comply with the emission standards. Continuous emission monitors are used to ensure compliance with the stan dards at all times. During the performance test, a record of the operating parameters under which compliance was achieved may be recorded and used to determine compliance in place of a continuous emission monitor. The notification s required in the standards are used to inform the Agency or delegated authority when a source becomes subject to the requirements of the regulations. The reviewing authority may then inspect the source to check if the pollution control devices are properly installed and operate d and leaks are being detected and repaired and the standards are being met. The performance test may also be observed. The required semiannual reports are used to determine periods of excess emissions, identify problems at the facility , verify operation/maintenance procedures and for compliance determinations. 3. Nonduplication, Consultations, and Other Collection Criteria The requested recordkeeping and reporting are required under 40 CFR part 63, subpart UUU. 3(a) Nonduplication If the subject s tandards have not been delegated, the information is sent directly to the appropriate EPA regional office. Otherwise, the information is sent directly to the delegated state or local agency . I f a state or local agency has adopted its own similar standard s to implement the Federal standards, a copy of the report submitted to the state or local agency can be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, no duplication exists.4

3(b) Public Notice Required Pri or to ICR Submission to OMB An announcement of a public comment period for the renewal of this I CR was published in the Federal Register ( 71 FR 58853) on October 6, 2006

. No comments were received on the burden published in the Federal Register

. 3(c) Consultations The assumptions made in the development of this I CR, including the estimate on the number of petroleum refineries subject to the standard, were reviewed and updated, if needed, by the Agency

in consultation with David Friedman of the Natio nal Petrochemical and Refiners Association (NPRA,) who consulted with some of its committee members. In addition, we consulted the Agency ’s internal data sources including our own industry experts and the AI RS Facility Subsy stem (AFS), which is the EPA da tabase for the collection, maintenance, and retrieval of all compliance data. The information in AFS is reported by industry , in compliance with the recordkeeping and reporting provisions in the standard. AFS is operated and maintained by the Office of C ompliance at EPA. We have estimated that there are approximately 132 existing respondents subject to the standard and no new sources will become subject to the standard over the three y ear period covered by this I CR. The Agency

also has the policy

to re spond after a thorough review of the comments received from the public since the last I CR renewal as well as those submitted in response to the First Federal Register Notice. In this case, no comments were received. 3(d) Effects of Less Frequent Colle ction Less frequent information collection would decrease the margin of assurance that facilities are continuing to meet the standards. Requirements for information gathering and recordkeeping are useful techniques to ensure that good operation and maint enance practices are applied and emission limitations are met. I f the information required by these standards was collected less frequently , the proper operation and maintenance of control equipment and the possibility

of detecting violations would be les s likely

. 3(e) General Guidelines These reporting or recordkeeping requirements do not violate any of the regulations promulgated by

OMB under 5 CFR part 1320, section 1320.5. These standards require the respondents to maintain all records, including r eports and notifications for at least five y ears. This is consistent with the General Provisions as applied to the standards. EPA believes that the five y ear records retention requirement is consistent with p art 70 permit program and the five y ear statute of limitations on which the permit program is based. The retention of records for five y ears allows EPA to establish the compliance history of a source, any

pattern of non

- compliance and to determine the appropriate level of enforcement5

action. EPA h as found that the most flagrant violators have violations extending beyond five ye ars. I n addition, EPA would be prevented from pursuing the violators due to the destruction or nonexistence of essential records. 3(f) Confidentiality Any information sub mitted to the Agency for which a claim of confidentiality is made will be safeguarded according to the Agency policies set forth in title 40, chapter 1, part 2, subpart B

- Confidentiality of Business I nformation (CBI ) (see 40 CFR 2; 41 FR 36902, September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979). 3(g) Sensitive Questions The reporting or recordkeeping requirements in the standard do not include sensitive questions. 4. The Respond ents and the Information Requested 4(a) Respondents/SIC Codes The respondents to the recordkeeping and reporting requirements are owners or operators of major source petroleum refineries. The United States Standard I ndustrial Classification (SI C) code for the respondents affected by the standards is code 2911 which corresponds to the North American Industry Classification Sy stem (NAI CS) code 32411 for petroleum refineries that operate cataly tic cracking units, cataly

tic reforming units, or sulfur recov ery units. 4(b) Information Requested (i) Data Items
Inthis I CR, all the data that is recorded or reported is required by NESHAP for Petroleum Refineries, Cataly

tic Cracking, Reforming and Sulfur Units (40 CFR part 63, subpart UUU).
A source must make the following reports: Notification Reports Notification of intention to construct or reconstruct 63.9(b)(5), 63.1574(a) Notification of anticipated date of initial startup 63.9(b)(4)(iv), 63.1574(a)6 Notification Reports Notification of commencement of construction 63.9(b)(4)(iii), 63.1574(a) Notification of the actual date of startup 63.9(b)(4)(v), 63.1574(a) Notification of performance tests 63.7(a) and 63.9(e), 63.1574(a) Notification of compliance status 63.9(g), 63.1574(d), (f) Request for compliance exte nsion 63.9(c), 63.1574(e)
Reports Semiannual compliance reports 63.10(e)(3), 63.1575 Startup, shutdown, and malfunction plan/reports 63.6(3), 63.10(d)(5), 63.1570, 63.1575 A source must keep the following records: Recordkeeping Maintain records of startup, shutdown, and malfunction plan/reports 63.1576(a)(2), 63.10(b)(2) Maintenance 63.10(b)(2)(iii), 63.1576(d) CMS/CEM malfunction 63.1576(b), 63.10(c) Emissions data 63.1576(a)(3), 63.10(d) Notification of compliance status 63.1576(a)(1), 63.9 (h) CEM quality

assurance plan 63.1576(b), 63.8(d) CEM general provisions 63.1576(b), 63.10(c) Records are required to be retained for 5 Years 63.10(c), 63.428(d) Electronic Reporting Some of the respondents are using monitoring equipment that automatically records parameter data. Although personnel at the affected facility must still evaluate the data, internal automation has significantly reduced the burden associated with monitoring and recordkeeping at a plant site.7

Also, regulatory

agencies in cooperation with the respondents, continue to create reporting sy stems to transmit data electronically . However, electronic reporting sy stems are still not widely

used. At this time, it is estimated that approximately 10 percent of the respondents use e lectronic reporting.

(ii) Respondent Activities

Respondent Activities Read instructions. In stall, calibrate, maintain, and operate CMS for opacity or emission monitoring for cataly tic cracking units, cataly

tic reforming units and sulfur recovery sy ste ms. Perform initial performance test, Reference Method 5B or 5F (40 CFR Part 60) test for PM , and repeat performance tests if necessary

. Write the notifications and reports listed above. Enter information required to be recorded above. Submit the requ ired reports developing, acquiring, installing, and utilizing technology and sy stems for the purpose of collecting, validating, and verifying information. Develop, acquire, install, and utilize technology and sy stems for the purpose of processing and main taining information. Develop, acquire, install, and utilize technology and sy stems for the purpose of disclosing and providing information. Train personnel to be able to respond to a collection of information. Transmit, or otherwise disclose the information. 5. The Information Collected: Agency Activities, Collection Methodology, and Information Management 5(a) Agency Activities EPA conducts the following activities in connection with the acquisition, analy sis, storage, and distribution of the re quired information. Agency Activities Review notifications and reports, including performance test reports, and excess emissions reports, required to be submitted by industry

. Audit facility

records. Input, analy

ze, and maintain data in the A IR S Facili ty S ubs ys tem (AFS). 5(b) Collection Methodology and Management8

Following notification of startup, the reviewing authority might inspect the source to determine whether the pollution control devices are properly installed and operated. Performance test reports are used by the Agency

to discern a source ’ s initial capability to comply with the emission standard. Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs. The semiannual repor ts are used for problem identification, as a check on source operation and maintenance, and for compliance determinations.
In formation contained in the reports is entered into the AFS which is operated and maintained by

the EPA Office of Compliance. AFS is the EPA database for the collection, maintenance, and retrieval of compliance and annual emission inventory data for over 100,000 industrial and government

- owned facilities. EPA uses the AFS for tracking air pollution compliance and enforcement by loca l and state regulatory agencies, EPA regional offices and EPA headquarters. EPA and its delegated a uthorities can edit, store, retrieve and analy ze the data. The records required by this regulation must be retained by the owner or operator for five ye ar s. 5(c) Small Entity Flexibility A majority

of the respondents are large entities (i.e., large businesses). However, the impact on small entities (i.e., small businesses) was taken into consideration during the development of the regulation. A small e ntity for petroleum refineries is defined as a firm having no more than 1,500 employ ees and no more than 75,000 barrels per day capacity corporately

. Numerous compliance and monitoring alternatives are provided in the rule to give small entities a maximum degree of operational flexibility . The rule requirements are considered to be the minimum necessary

to demonstrate compliance. Under section 112(i) of the Clean Air Act, the Administrator or applicable permitting authority also may grant 1 additional y e ar if more time is needed to install controls for a source. This additional time will ease any capital availability

problems for plants in marginal economic condition. The Agency

expected three affected units to qualify for the compliance extension. 5( d) Collection Schedule The specific frequency

for each information collection activity within this request is shown in Table 1: NESHAP for Petroleum Refineries, Cataly tic Cracking, Reforming and Sulfur Units (40 CFR p art 63, s ubpart UUU). 6. Estimating the Burden and Cost of the Collection Table 1 documents the computation of individual burdens for the recordkeeping and9

reporting requirements applicable to the industry for each of the subpart s included in this I CR. The individual burdens are expressed under standardized headings believed to be consistent with the concept of burden under the Paperwork Reduction Act. Where appropriate, specific tasks and major assumptions have been identified. Responses to this information collection are mandatory

. Th e Agency

may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it display s a currently valid OMB Control Number. 6(a) Estimating Respondent Burden The average annual burden to industry over the next t hree y ears from these recordkeeping and reporting requirements is estimated to be 11,0 40 ( Total L abor Hours from Table 1). The recordkeeping hours shown in Table 1 are 7,9 36.2 . The reporting requirement hours shown in Table 1 are 3, 1 0 3. 4 . These hours are based on Agency studies and background documents from the development of the regulation, Agency knowledge and experience with the NESHAP program, the previously

approved I CR, and any

comments received. 6(b) Estimating Respondent Costs (i) Estimating Labor Costs This I CR uses the following labor rates: Managerial $105.86 ($50.41 + 110%) Technical $92.61 ($44.10 + 110%) Clerical $45.32 ($21.58 + 110%) These rates are from the United States Department of Labor, Bureau of Labor Statistics, December 2006, Table 2. Civilian Workers, by occupational and industry group. The rates are from column 1, Total compensation. The rates have been increased by 110% to account for the benefit packages available to those employ ed by p rivate industry

. (ii) Estimating Capital/Startup and Operation and Maintenance Costs The ty pe of industry

costs associated with the information collection activities in the subject standards are both labor costs which are addressed elsewhere in this I CR and the costs associated with continuous monitoring. The capital/startup costs are one time costs when a facility becomes subject to the regulation. There is no capital cost for continuous monitoring since we have assumed that all existing respondent have installed the necessary equipment for monitoring and for file storage, as described in the total of column D below. The annual operation and maintenance costs are the ongoing costs to maintain continuous emission monitors (CEMS), continuous opacity m onitors10

(COMS) and/or parametric monitors (CPMS) at the affected facilities including fuel cataly tic cracking units (FCCUs), cataly tic reforming units (CRUs) and sulfur recovery units (SRUs), and other costs such as photocopying and postage, as described b elow. We have assumed that a respondent would monitor the affected emission units either using a CEMS or CPMS.

(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs Capital/Startup vs. Operation and Maintenance (O&M) Costs (A) Continuous Mo nitoring Device (B)

Capital/Startup Cost for One Affected Facility (C)

Number of New Affected Facilities (D)

Total Capital/Startup Cost (B X C) (E)

Annual O&M Costs for One Affected Facility (F)

Number of Affected Facilities with O&M (G)

Total O&M, (E X F)

COMS (FCCUs) $95,700 0 $0.00 $28,600 13 371,800 CPMS (FCCUs) $18,900 0 $0.00 $25,350 43 $1,090,050 CPMS (CRUs) $0.00 0 $0.00 $24,056 * 132 $3,175,392 CPMS (SRUs) $74,000 0 $0.00 $26,000 84 $2,184,000 CEMS (SRUs) $150, 000 0 $0.00 $34,840 29 $1,010,3 60 TOTAL $0.00 $6,850,602 * Note: We estimate that there are 177 CRUs using CPMs for monitoring (i.e., an average of 1.34 CRUs per respondent ) at a cost of $17,940 per CPMS w hich total $24,056 per respondent. The annual cost for capital/startup and operation and maintenance costs to industry over the next three y ears of the I CR are estimated to be $6,850,602. There are no capital costs in the renewal of this I CR since existing sources have already installed the necessary

monitoring equipment to c omply

with the standard, as described in the total of column D, above. The operation and maintenance costs to industry over the next three y ears of the I CR are estimated to be $6,850,602, as described in Column G, above. We have determined that many of t he FCCUs and SRUs are now subject to the NSPS requirements and the associated monitoring would not be attributed to this I CR. 6(c) Estimating Agency Burden and Cost The only costs to the Agency

are those costs associated with analy sis of the reported i nformation. EPA's overall compliance and enforcement program includes activities such as the review examination of records maintained by the respondents, periodic inspection of sources of emissions, and the publication and distribution of collected inform ation.
The average annual Agency cost during the three y ears of the I CR is estimated to be $25,813 ( see Table 2 attached .)11

This cost is based on the average hourly labor rate as follows: Managerial $58.18 (GS

- 13, Step 5, $36.36 + 60%) Technical $43 .17 (GS

- 12, Step 1, $26.98 + 60%) Clerical $23.36 (GS

- 6, Step 3, $14.60 + 60%) These rates are from the Office of Personnel Management (OPM) 2007 General Schedule , which excludes locality

rates of pay . The rates have been increased by 60% to account f

or the benefit packages available to government employ ees. Details upon which this estimate is based appear in Table 2: NESHAP for Petroleum Refineries, Cataly tic Cracking, Reforming and Sulfur Units (40 CFR p art 63, s ubpart UUU), attached. 6(d) Estimat ing the Respondent Universe and Total Burden and Costs Based on our research for this I CR, on average over the next three y ears, approximately 132 existing respondents will be subject to the standard. It is estimated that no additional respondents per y e ar will become subject to the standard. However, it is estimated that three affected emission source units had qualified for a compliance date extension and would be complying with the initial compliance requirements during the period of this I CR (one per ye ar) and one affected facility

(0.33 per y ear) will conduct a performance test due to a process/operating change. The overall average number of respondents per y ear subject to this standard is calculated using the following table that addresses the thre e y ears covered by this IC R. Number of Respondents

Respondents That Submit Reports Respondents That Do Not Submit Any Reports Year (A) Number of New Respondents 1 (B)

Number of Existing Respondents (C)

Number of Existing Respondents that keep records but do not submit reports (D)

Number of Existing Respondents That Are Also New Respondents (E)

Number of Respondents (E=A+B+C

- D)

1 1.3 132 0 1.3 132 2 1.3 132 0 1.3 132 3 1.3 132 0 1.3 132 Average 1.3 132 0 1.3 132

1 New respondents include sources w ith constructed, reconstructed and modified affected facilities. In this standard existing respondents submit initial notifications.

. Column D is subtracted to avoid double

- counting respondents. As shown above, the average Number of Respondents over the three

- ye ar period of this I CR is 132. The total number of annual responses per y ear is calculated using the following table:12 Total Annual Responses (A) Information Collection Activity (B) Number of Respondents (C)

Number of Responses (D)

Number of Exi sting Respondents That Keep Records But Do Not Submit Reports (E)

Total Annual Responses E=(BxC)+D

Notification of performance test 1.33 1 0 1.33 Semiannual compliance report 2 132 0 264 Total 265.33 The number of Total Annual Responses is 265 (rounded). The total annual labor costs are $98 3 , 339 (rounded). Details regarding these estimates may be found in Table 1. Annual Respondent Burden and Cost, NESHAP for Petroleum Refineries, Cataly tic Cracking, Reforming and Sulfur Units (40 CFR p art 63, s ub part UUU), attached. 6(e) Bottom Line Burden Hours Burden Hours and Cost Tables The detailed bottom line burden hours and cost calculations for the respondents and the Agency are shown in Tables 1 and 2, respectively , and summarized below. (i) Respond ent Tally The total annual labor hours are 11,0 40 . Details regarding these estimates may be found in Table 1. Annual Respondent Burden and Cost, NESHAP for Petroleum Refineries, Cataly tic Cracking, Reforming and Sulfur Units (40 CFR Part 63, Subpart UUU) , attached. Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 42 hours (rounded) per response. The total annual capital/startup and O&M costs to the regulated entity are $6,850,60 2

. The cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M) Costs.

(ii) The Agency Tally The average annual Agency burden and cost over next three y ears is estimated to be 620 labor hours (rounded) at a cost of $25,813 (rounded). See Table 2. Annual Agency Burden and Cost, NESHAP for Petroleum Refineries, Cataly tic Cracking, Reforming and Sulfur Units (40 CFR p art 63, s ubpart UUU), attached. 6(f) Reasons for Change in Burden13

The decrease in burden f

rom the most recently

approve d I CR is due to an adjustments

. The decrease in the total estimated burden as currently identified in the OMB Inventory of Approved Burden is not due to any program changes. The change in the burden and cost estimates occurre d because the standard has been in effect for more than three y ears and the requirements are different during initial compliance (new facilities) as compared to on

- going compliance (existing facilities). The previous I CR reflected those burdens and costs associated with the initial activities for subject facilities. This includes purchasing monitoring equipment, conducting performance test s and establishing recordkeeping sy stems. This I CR reflects the on

going burden and costs for existing facilities sin ce we have assumed that there are no new sources. Activities for existing source include continuously monitoring of pollutants and the submission of semiannual reports. The overall result is a decrease in labor burden hours. However, the annual costs in creased due to the inclusion of operation and maintenance costs for existing monitoring sy stems , all of which are assumed to be operating after the compliance date of the rule. 6(g) Burden Statement The annual public reporting and recordkeeping burden f or this collection of information is estimated to average 42 hours (rounded) per response. Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federa l agency . This includes the time needed to review instructions; develop, acquire, install, and utilize technology and sy stems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing way s to comply with any previously

applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of inform ation; and transmit or otherwise disclose the information. An agency

may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it display s a valid OMB Control Number. The OMB Control Numbers for EPA ’ s regu lations are listed at 40 CFR part 9 and 48 CFR chapter 15. To comment on the Agency 's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated col lection techniques, EPA has established a public docket for this I CR under Docket I D Number EPA

- HQ

- OECA

- 2006

- 0752. An electronic version of the public docket is available at http://www.regulations.gov/ which may be used to obtain a copy

of the draft colle ction of information, submit or view public comments, access the index listing of the contents of the docket, and to access those documents in the public docket that are available electronically . When in the sy stem , select “search,” then key in the docket ID number identified in this document. The documents are also available for public viewing at the Enforcement and Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Avenue, NW, Washington, D C. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday , excluding legal14

holiday s. The telephone number for the Reading Room is (202) 566

- 1744, and the telephone number for t he docket center is (202) 566

- 17 52 . Also, y ou can send comments to the Office of In formation and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket I D Number EPA

- HQ

- OECA

- 2006

- 075 2 and OMB Control Number 2060

- 0554 in any correspondence. Part B of the Supporting Statement This part is not applicable because no statistical methods were used in collecting this information.1516

Table 1. Annual Respondent Burden and cost: NESHAP for Petroleum Refineries, Catalytic Cracking, Reforming and Sulfur Units (40 CFR part 63, subpart UUU)

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)

Cost,$ b

1. Applications N/A 2. Survey and Studies N/A 3. Acquisition, Installation, and Utilization of Technology and Systems 40 1 40 0 0.0 0.0 0.0 $0.00

4. Reporting Requirements A. Read instructions c 2 1 2 1.33 2.7 0.1 0.3 $274.24 B. Required activities c Initial Performance test c 40 1 40 1 40.0 2.0 4.0 $4,097.40 Performance test d 40 1 40 0.33 13.2 0.7 1.3 $1,355.47 Startup, shutdown, malfunction Plan 40 1 40 0 0.0 0.0 0.0 $0.00 Operating, maintenance, a nd mo nitoring plan b 40 1 40 0 0.0 0.0 0.0 $0.00

C. Create information See 4B D. Gather existing information See 4B E. Write report17

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)

Cost,$ b

Notification of construction/ reconstruction 2 1 2 0 0.0 0.0 0.0 $0.00 Notification of actual startup 2 1 2 0 0.0 0.0 0.0 $0.00 Notification of special compliance requirements N/A

Notification o f performance test b 2 1 2 1.33 2.7 0.1 0.3 $274.24
Notification of compliance Status b 4 1 4 0 0.0 0.0 0.0 $0.00 Extended compliance request N/A Report of performance test c See 4B Semiannual compliance reports e 10 2 20 132 2,640.0 132.0 264.0 $270,428.40
5. Recordkeeping Requirements A. Read instructions See 4A B. Plan activities c See 4B C. Implement activ ities c See 4B D. Develop record system f N/A18

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)

Cost,$ b

E. Time to enter information g& h
Records of operations 1 52 52 132 6,864.0 343.2 686.4 $703,113.84 F. Time to train personnel 4 1 4 1 4 0.0 2 0. 4 $ 409.74 G. Time to adjust existing ways to comply with previously applicable requirements N/A

H. Time to transmit or disclose Information b& i 0.25 1 0.25 132 33.0 1.7 3.3 $3,385.65

I. Time for audi ts N/A Subtotal Labor Burden 9,596.9 479.9 959.74 $983, 338.98
TOTAL LABOR BURDEN AND COST 11,0 40 $983,339Assumptions:

a W e have determined that of the 164 existing major source petroleum refineries in the U.S . and its territories, of w hich 132 of these operate at least one of the affected sources subject to this rule. Furthermore, we have estimated that there is an average of 486 affected units at the 132 major source petroleum refineries. No new or reconstr

ucted facilities are expected over the next 3 years. b This ICR uses the following labor rates: $105.86 per hour for Executive, Administrative, and Managerial labor; $92.61 per hour for Technical labor, and $45.32 per hour for Clerical labor. These rate s are from the United States Department of Labor, Bureau of Labor Statistics, September 2006, A Table 2. Civilian Workers, by occupational and industry group. @ The rates are from column 1, A 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 that all existing respondents (132 major source petroleum refineries) over 3

- year term of ICR have complied with rule initial requirements including the initial performance test. How ever, it w as estimated that 3 affected units had qualified for the compliance date extension due to installation of control equipment and therefore, would be complying with the initial performance test during the period of this ICR (one per year). d We have assumed that one respondent over 3

- year term of ICR will conduct a performance test due to significant process/operating change (1/3 = 0.333).
e All sources would be submitting semiannual compliance reports. f W e have assumed that sources have already the record system in place to monitor operations. g Depending on the compliance option for the affected facility (i.e., catalytic cracking unit, sulfur recovery units, and by

- pass lines) selected by the responden t and the size of the catalytic cracking unit and control device used (e.g., wet scrubber, electrostatic precipitator and therm al incinerators), sources are required to either installed c ontinuous opacity monitoring systems and/or continuous parameter moni toring, or choose an alternative option for parameter monitoring. h We have assumed that all respondents would have to keep records of their operations according to the operation and maintenanc e plan. i We have assumed that it takes respondents approx imate one hour to record data per w eek (52 w eeks) and 15 minutes to transmit it semiannually. N/A Not applicable.Table 2. Annual Burden and Cost to the Federal/State Government: NESHAP for Petroleum Refineries, Catalytic Cracking,

Reforming and Sulfu r Units (40 CFR part 63, subpart UUU)

Activity (A) Hours per occurrence (B)

Hours per plant per year (C)

Plants per year (D)

Technical person - hours per year (D=BxC) (E)

Management person - hours per year (Dx0.05) (F)

Clerical person - hours per ye ar (Dx0.1) (G)

Cost, $ a

Report Review Notification of construction/reconstruction N/A Notification of actual startup N/A Notification of special compliance requirements N/A N otification of initial performance test b 2 2 1.33 2.7 0.1 0.3 $129.39 Notification of performance test c 2 2 1.33 2.7 0.1 0.3 $129.39 Notification of compliance status 2 2 0 0 0.0 0.0 $0.00 Review of operation, maintenance, and mo nitoring plan b 4 4 0 0 0.0 0.0 $0.00 Review of repeat performance test report 8 8 0 0 0.0 0.0 $0.00 Review of compliance report N/A Review of semiannual compliance reports d 2 4 132 528 26.4 52.8 $25,553.77 Review of NESHAP waiver application 4 4 0 0.0 0.0 0.0 $0.00 Subtotal Burden and Cost 533.4 26.6 53.8 $25,812.55 TOTAL BURDEN AND COST (SALARY) 614 $25,813

Assumptions:
a This cost is based on the follow ing labor rates: Manager ial rate of $58.18 (GS

- 13, Step 5, $36.36 + 60%), Technical rate of $43.17 (GS

- 12, Step 1, $26.98 + 60%), and Clerical rate of $23.36 (GS

- 6, Step 3, $14.60 + 60%). These rates are from the Office of Personnel Management (OPM) A 2007 General Schedule @21

which excludes locality rates of pay. b We have assumed that all existing respondents (132 major source petroleum refineries) over 3

- year term of ICR has comply with rule initial requirements including the initial performance test. How ever, it w as estimated that 3 affected units had qualified for the compliance date extension due to installation of control equipment and therefore, would be complying with the initial performance test during the period of this ICR (one per year).
c We have assumed that on e respondent over 3

- year term of ICR will conduct a performance test due to significant process/operating change (1/3 = 0.333). d All sources would be submitting semiannual compliance reports. N/A Not applicable.