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 Refineries, Catalytic Cracking, Reforming and Sulfur Units (40 

CFR part 63, subpart 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, subpart UUU, were proposed on September 11, 1998, 

promulgated on April 11, 2002, and amended on February 9, 2005. These regulations apply to 

three types of affected sources at major source petroleum refineries. The three affected sources 

are: the fluid catalytic cracking unit catalyst regeneration; the catalytic reforming unit catalyst 

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 that 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 affected source and compliance option, the rule may require a continuous opacity monitoring 

system, a continuous emission monitoring system, a continuous parameter monitoring system, 

manual inspections, and/or calculations. Continuous opacity monitoring systems and continuous 

emission monitoring systems 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).

In general, all NESHAP standards require initial 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 system 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 years 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 of the 
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164 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 years. 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 ICR 

(one per year) and one affected facility (0.33 per year) will conduct a performance test due to a 

process/operating change. The 132 respondents to this ICR are publicly owned and operated by

petroleum 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, 

Catalytic 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 employees or 

government contractors. The burden to the Federal Government can be found in Table 2: Annual 

Burden and Cost to the Federal/State Government: NESHAP for Petroleum Refineries, Catalytic 

Cracking, Reforming and Sulfur Units (40 CFR part 63, subpart UUU). 

The Office of Management and Budget (OMB) approved the currently active ICR 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. In addition, 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 control 

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.
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In the Administrator's judgment, metal hazardous air pollutants (HAP) and organic HAP 

emissions from catalytic cracking units; organic and inorganic HAP emissions from catalytic 

reforming units; and HAP emissions from sulfur recovery units and bypass 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 Utility/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 inspections 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 standards 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 notifications 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 operated 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 standards 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. If a state or local agency has adopted its own similar standards 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.
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3(b) Public Notice Required Prior to ICR Submission to OMB

An announcement of a public comment period for the renewal of this ICR 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 ICR, 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 National 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 AIRS 

Facility Subsystem (AFS), which is the EPA database 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 Compliance 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 year period covered by this ICR.

The Agency also has the policy to respond after a thorough review of the comments 

received from the public since the last ICR 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 Collection

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 maintenance practices are 

applied and emission limitations are met. If 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 less 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 reports and 

notifications for at least five years. This is consistent with the General Provisions as applied to 

the standards. EPA believes that the five year records retention requirement is consistent with 

part 70 permit program and the five year statute of limitations on which the permit program is 

based. The retention of records for five years allows EPA to establish the compliance history of 

a source, any pattern of non-compliance and to determine the appropriate level of enforcement 
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action. EPA has found that the most flagrant violators have violations extending beyond five 

years. In addition, EPA would be prevented from pursuing the violators due to the destruction or 

nonexistence of essential records.

3(f) Confidentiality

Any information submitted 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 Information (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 Respondents 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 Industrial 

Classification (SIC) code for the respondents affected by the standards is code 2911 which 

corresponds to the North American Industry Classification System (NAICS) code 32411 for 

petroleum refineries that operate catalytic cracking units, catalytic reforming units, or sulfur 

recovery units.

4(b) Information Requested

(i) Data Items

In this ICR, all the data that is recorded or reported is required by NESHAP for Petroleum 

Refineries, Catalytic 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)
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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 extension 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. 
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Also, regulatory agencies in cooperation with the respondents, continue to create 

reporting systems to transmit data electronically. However, electronic reporting systems are still 

not widely used. At this time, it is estimated that approximately 10 percent of the respondents 

use electronic reporting.

(ii) Respondent Activities

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate CMS for opacity or emission monitoring for catalytic 

cracking units, catalytic reforming units and sulfur recovery systems. 

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 required reports developing, acquiring, installing, and utilizing technology and 

systems for the purpose of collecting, validating, and verifying information.

Develop, acquire, install, and utilize technology and systems for the purpose of processing and 

maintaining information.

Develop, acquire, install, and utilize technology and systems 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, analysis, 

storage, and distribution of the required 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, analyze, and maintain data in the AIRS Facility Subsystem (AFS).

5(b) Collection Methodology and Management
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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 reports are used for 

problem identification, as a check on source operation and maintenance, and for compliance 

determinations.

Information 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 local and state regulatory agencies, EPA regional offices and 

EPA headquarters. EPA and its delegated authorities can edit, store, retrieve and analyze the 

data. 

The records required by this regulation must be retained by the owner or operator for five 

years.

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 entity for petroleum refineries is defined as a firm having 

no more than 1,500 employees 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 year 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, Catalytic Cracking, Reforming and Sulfur 

Units (40 CFR part 63, subpart UUU).

6. Estimating the Burden and Cost of the Collection

Table 1 documents the computation of individual burdens for the recordkeeping and 
9

reporting requirements applicable to the industry for each of the subparts included in this ICR. 

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.

The Agency may not conduct or sponsor, and a person is not required to respond to, a 

collection of information unless it displays a currently valid OMB Control Number.

6(a) Estimating Respondent Burden

The average annual burden to industry over the next three years from these recordkeeping 

and reporting requirements is estimated to be 11,040 ( Total Labor Hours from Table 1). The 

recordkeeping hours shown in Table 1 are 7,936.2. The reporting requirement hours shown in 

Table 1 are 3,103.4. 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 ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR 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 employed by private industry.

(ii) Estimating Capital/Startup and Operation and Maintenance Costs

The type of industry costs associated with the information collection activities in the 

subject standards are both labor costs which are addressed elsewhere in this ICR 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 monitors 
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(COMS) and/or parametric monitors (CPMS) at the affected facilities including fuel catalytic 

cracking units (FCCUs), catalytic reforming units (CRUs) and sulfur recovery units (SRUs), and 

other costs such as photocopying and postage, as described below. 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 

Monitoring 

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 $1,010,360

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 which total $24,056 per respondent.

The annual cost for capital/startup and operation and maintenance costs to industry over 

the next three years of the ICR are estimated to be $6,850,602. There are no capital costs in the 

renewal of this ICR since existing sources have already installed the necessary monitoring 

equipment to comply with the standard, as described in the total of column D, above. The 

operation and maintenance costs to industry over the next three years of the ICR are estimated to 

be $6,850,602, as described in Column G, above. We have determined that many of the FCCUs 

and SRUs are now subject to the NSPS requirements and the associated monitoring would not be 

attributed to this ICR. 

6(c) Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of the reported 

information. 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 information. 

The average annual Agency cost during the three years of the ICR is estimated to be 

$25,813 (see Table 2 attached.)
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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 for the benefit 

packages available to government employees. Details upon which this estimate is based appear 

in Table 2: NESHAP for Petroleum Refineries, Catalytic Cracking, Reforming and Sulfur Units 

(40 CFR part 63, subpart UUU), attached.

6(d) Estimating the Respondent Universe and Total Burden and Costs

Based on our research for this ICR, on average over the next three years, approximately

132 existing respondents will be subject to the standard. It is estimated that no additional 

respondents per year 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 ICR (one per year) 

and one affected facility (0.33 per year) will conduct a performance test due to a 

process/operating change. The overall average number of respondents per year subject to this 

standard is calculated using the following table that addresses the three years covered by this 

ICR. 

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 with 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-year period of this ICR is 132.

The total number of annual responses per year is calculated using the following table: 
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Total Annual Responses

(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

Notification of performance 

test

1.33 10 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 $983,339 (rounded). Details regarding these estimates may be found in Table 1. Annual 

Respondent Burden and Cost, NESHAP for Petroleum Refineries, Catalytic Cracking, Reforming 

and Sulfur Units (40 CFR part 63, subpart 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) Respondent Tally

The total annual labor hours are 11,040. Details regarding these estimates may be found 

in Table 1. Annual Respondent Burden and Cost, NESHAP for Petroleum Refineries, Catalytic 

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 $6,850,602. 

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 years 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, Catalytic Cracking, Reforming and Sulfur Units (40 

CFR part 63, subpart UUU), attached.

6(f) Reasons for Change in Burden
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The decrease in burden from the most recently approved ICR 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 occurred because the standard has been in effect for more than three years and the 

requirements are different during initial compliance (new facilities) as compared to on-going 

compliance (existing facilities). The previous ICR reflected those burdens and costs associated 

with the initial activities for subject facilities. This includes purchasing monitoring equipment, 

conducting performance tests and establishing recordkeeping systems. This ICR reflects the ongoing burden and costs for existing facilities since 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 increased due to the inclusion of operation and maintenance costs for 

existing monitoring systems, 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 for 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 Federal agency. This includes the time needed to review instructions; 

develop, acquire, install, and utilize technology and systems for the purposes of collecting, 

validating, and verifying information, processing and maintaining information, and disclosing 

and providing information; adjust the existing ways 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 information; 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 displays a valid OMB Control Number. The OMB Control 

Numbers for EPA’s regulations 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 collection techniques, EPA has established a public docket for this ICR under 

Docket ID 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 

collection 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 system, 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, DC. The EPA Docket Center Public 

Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal 
14

holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone 

number for the docket center is (202) 566-1752. Also, you can send comments to the Office of 

Information 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 ID 

Number EPA-HQ-OECA-2006-0752 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.
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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)

Personhours per

occurrence

(B) 

No. of

occurrences

per 

respondent

per year

(C)

Personhours per

respondent

per year

(C=AxB)

(D)

Respondents

per year a

(E)

Technical

personhours per

year

(E=CxD)

(F)

Management

person-hours

per year

(Ex0.05)

(G)

Clerical

personhours 

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 c2 1 2 1.33 2.7 0.1 0.3 $274.24

B. Required activities c

 Initial Performance test c40 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, and

 monitoring 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 report
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Burden item

(A)

Personhours per

occurrence

(B) 

No. of

occurrences

per 

respondent

per year

(C)

Personhours per

respondent

per year

(C=AxB)

(D)

Respondents

per year a

(E)

Technical

personhours per

year

(E=CxD)

(F)

Management

person-hours

per year

(Ex0.05)

(G)

Clerical

personhours 

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 of 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 cSee 4B

C. Implement activities cSee 4B

D. Develop record system f N/A
18

Burden item

(A)

Personhours per

occurrence

(B) 

No. of

occurrences

per 

respondent

per year

(C)

Personhours per

respondent

per year

(C=AxB)

(D)

Respondents

per year a

(E)

Technical

personhours per

year

(E=CxD)

(F)

Management

person-hours

per year

(Ex0.05)

(G)

Clerical

personhours 

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 0.02 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 audits N/A

Subtotal Labor Burden 9,596.9 479.9 959.74 $983,338.98

TOTAL LABOR BURDEN AND 

COST

11,040 $983,339
Assumptions:

a

 We have determined that of the 164 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 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 rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2006, ATable 2. Civilian Workers, 

by occupational and industry group.@ The rates are from column 1, ATotal 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. However, it was 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

 We 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 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 installed continuous opacity monitoring systems and/or continuous parameter monitoring, 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 maintenance plan.

i

 We have assumed that it takes respondents approximate one hour to record data per week (52 weeks) 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 Sulfur 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 year

(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

 Notification of initial performance test b2 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

 monitoring 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 following labor rates: Managerial 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) A2007 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. However, it was 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 one 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.