1 SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY NSPS SUBPART Ja STANDARDS OF PERFORMANCE FOR PETROLEUM REFINERIES DECEMBER 2011

1. Identification of the Information Collection

1(a) Title of the Information collection

ICR for Standards of Performance for Petroleu m Refineries (40 CFR part 60, subpart Ja). This is a revision of an existing information collection request (ICR); the OMB Control Number is 2060-0602 and the EPA tracking number is 2263.03.

1(b) Short Characterization/Abstract

The EPA is revising 40 CFR part 60, subpart Ja as it applies to pro cess heaters that are constructed, reconstructed, or modified afte r May 14, 2007 and flares that are constructed, reconstructed, or modified after June 24, 2008. Emissions limitations, which include hydrogen sulfide (H 2 S) concentration limits, will be used to control emissions of nitrogen oxides (NO X ) and sulfur dioxide (SO 2 ). Other standards will apply to flar ing of fuel gases, which will reduce emissions of NO X , SO 2 , carbon monoxide (CO), and volatile organic compounds (VOC). These standards will require plants to conduct an analysis of any exceedance or discharge of SO 2 emissions that exceeds 500 pounds in 24 hours or a discharge to a flare exceeding 500,000 standard cubic feet in 24 hours a bove the baseline flow to the flar e. Plants will be required to monitor the sulfur content and th e flow to an affected flare to determine if they exceed these thresholds. Plants will also be re quired to prepare written plans to describe the flare, identify the process units connected to the flare, and descri be methods to minimize emissions from planned startup and shutdown of process units.

Plants will be required to use continu ous monitoring systems (CMS) or continuous emissions monitoring systems (CEMS), depending on the type and size of unit, pollutant, and control device. Alternative monitoring options ar e included for small process heaters and fuel gases with intrinsically low H 2 S concentrations. In general, all NSPS recordkeeping and reporting requirements for initial notifications, pe rformance test reports, reports of performance evaluations, and periodic reports of excess emi ssions will apply. Records of certain information listed in the rule will also be required to demonstrate conformance with specific rule requirements.

The previous ICR for this subpart (2263.02) included estimates of the monitoring, recordkeeping, and reporting burd en for affected sources at 18 plants, including process units and flares. This ICR estimates burden for 382 add itional flares expected to become affected facilities at 132 additional refineries over the first three years (f or a total of 400 affected flares at 150 refineries over the first three years).2 2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under Section 111 of the Clean Air Act (CAA), as amended, to establish standards of performance for new stationary sources that reflect:

“. . . application of the best technological system of continuous emissions reduction which (taking in to consideration the cost of achieving such emissions reduction, or any non-air quality health and environmental impact and energy requirements) the Administrator determines has been adequately demonstrated.” Section 111(a)(l).

The Agency refers to this charge as selec ting the best demonstrated technology. Section 111 also requires that the Admini strator review and, if appropriat e, revise such standards every eight years. In the Administ rator’s judgment, particulate matter, carbon monoxide, nitrogen oxides, and sulfur oxides emissions from petroleum refineries cause or contribute to air pollution that may reasonably be anticipated to endanger p ublic health or welfare. Therefore, NSPS were promulgated for this source category at 40 CFR part 60, subpart J and 40 CFR part 60, subpart Ja, and those standard s are being revised.

2(b) Practical Utility/ Users of the Data

The required notifications are us ed to inform the Agency or delegated authority when a source becomes subject to the standard. The revi ewing authority may then inspect the source to check if the pollution control devices are properly installed and operated and that the standard is being met. Performance test reports are needed as these are the Agency’s record of a source’s initial capability to comply w ith the emission standard, and/or note the operating conditions ( e.g. , maximum hydrogen sulfide levels in the fuel gas) under which compliance was achieved. The semiannual reports are used for problem identification, as a check on source operation and maintenance, and for compliance determinations.

The EPA reduced the reporting frequency fo r this information from quarterly to semiannually. The information generated by the monitoring, record keeping and reporting requirements described in this ICR is used by the Ag ency to ensure that facilities affected by the NSPS continue to operate the control equipmen t and achieve compliance with the standards. Adequate monitoring, recordkeeping, and reporting are necessary to ensure compliance with the applicable regulations, as required by the Cl ean Air Act. The information collected from recordkeeping and reporting requirements is also used for targeting inspections.

3. Nonduplication, Consultations, and Other Collection Criteria

The recordkeeping and reporting requested is re quired for sources subject to 40 CFR part 60, subpart Ja. Existing refineries that are major sources of hazardous air po llutants are subject to maximum achievable control t echnology (MACT) standards u nder 40 CFR part 63 subparts CC and UUU for the control of hazar dous air pollutants. Many refineries will also have existing3 sources that are subject to the emission limita tions and associated m onitoring, recordkeeping, and reporting requirements for criteria pol lutants in 40 CFR part 60, subpart J.

3(a) Nonduplication

If the subject standards have not been delega ted, the information is sent directly to the appropriate EPA Regional Office. Otherwise, the information is sent directly to the delegated State or local agency. The flare management plan that is sent to EPA’s Office of Air Quality Planning and Standards (OAQPS) is an exact copy of the flare mana gement plan sent to the EPA Regional Office or State or local agency. If a Stat e or local agency has adopted their own similar standards to implement the Federa l 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.

3(b) Public Notice Required Prio r to ICR Submission to OMB

This section is not applicable because this is a rule-related ICR.

3(c) Consultations

The EPA provided a 45-day public comment peri od after proposal of the amendments to NSPS subpart Ja. All affected parties were gi ven the opportunity to comment on the proposed standards during this period. The EPA considered all of the comments received and incorporated many of them in developi ng the final standards.

During development of the proposed and promul gated standards, the EPA held meetings and conference calls with representatives of petroleum refining companies and their trade associations (National Petrochemicals and Re finers Association and American Petroleum Institute). While these meetings were generally focused on the standards for process heaters and flares, alternative monitoring, recordkeeping, and reporting requi rements for certain types of flares were discussed, and an alternative water seal monitori ng approach was developed that reduces the burden estimates associated with mon itoring certain types of flares. Meeting minutes and supporting documentation of the issues discussed during these meeting are included in the docket for this rulemaking (EPA-HQ-OAR-2007-0011).

3(d) Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of assurance that facilities are continuing to meet the standard s. 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 likelihood of de tecting poor operation and maintenance of control equipment and noncompliance would decrease.4 3(e) General Guidelines

None of the reporting or recordkeeping requirements contained in 40 CFR part 60, subpart Ja or otherwise pertinen t to this request violate any of the regulations established by OMB at 5 CFR 1320.6.

3(f) Confidentiality

The required information consists of emissions data and other information that have been determined not to be private. However, any information submitted to the Agency for which a claim of confidentiality is made will be safeguard ed according to the Agency policies set forth in Title 40, Chapter 1, Part 2, Subpart B – Confiden tiality of Business Information (see 40 CFR Part 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

None of the reporting or recordkeeping requirements contained in 40 CFR part 60, subpart Ja or otherwise pertinent to th is request contain sensitive questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents of the recor dkeeping and reporting requirement s in this ICR are affected flares at petroleum refineries which commence construction, modifi cation, or reconstruction after June 24, 2008. The SIC code for the respondents aff ected by the standards is SIC (U.S. Standard Industrial Classification) 2911 which correspond s to the NAICS (North American Industry Classification System) 324110 for petroleum refineries.

4(b) Information Requested

(i) Data Items

All data in this ICR that are recorded and/ or reported are required by the Standards of Performance for Petroleum Refineries (40 CFR part 60, subpart Ja).

A source responding to this ICR must make the following reports:5 Reports for 40 CFR Part 60, Subpart Ja
Initial notifications: 60.7(a)

Construction/reconstruction 60.7(a)(1)

Actual Start-up 60.7(a)(3)

Physical or Operational Change 60.7(a)(4)

Demonstration of continuous monitoring system (CMS) 60.7(a)(5)
Excess emissions report 60.7(c), 60.108a(f) Initial performance test results 60.8(a) Notification of initial pe rformance test 60.8(d) Notification of Compliance status 60.11(a),(b),(c) Written flare management plans/root cause analyses/corrective action analyses 60.103a(a)-(e), 60.108a(d)

A source responding to this ICR must keep the following records:

Recordkeeping for 40 CFR Part 60, Subpart Ja Start-ups, shutdowns, malfunctions , periods where the continuous monitoring system is inoperative 60.7(b)

All reports and notifications 60.7

Emission test methods and other data needed to determine emissions 60.104a Written plans, information to document conformance with operation and maintenance requirements, monitoring exemptions, discharges to flare gas system, results of root cause an alyses and corrective action analyses 60.108a

(ii) Respondent Activities

Respondent Activities

Read instructions.

Gather relevant information. Perform initial performance test, Reference Method 1-6, 8-11, 15. Write the notifications and reports listed above. Enter information required to be recorded above.6 Respondent Activities Submit the required reports developing, acquirin g, installing, and uti lizing technology and systems for the purpose of collecting, validating, and verifying information. Develop, acquire, install, and ut ilize technology and systems for the purpose of processing and maintaining information. Develop, acquire, install, and ut ilize technology and systems for the purpose of disclosing and providing information. Adjust the existing ways to comply with a ny previously applicable instructions and requirements. Train personnel to be able to res pond to a collection of information.
Transmit, or otherwise disclose the information.

Continuous monitoring system (CMS) informa tion collection is automated and may be submitted electronically. In any event, hard copy reports from the CEMS information may easily be generated from a computer. It is estimated that 70 percent of the respon ses to this ICR can be collected electronically.

5. The Information Collected – Agency Activities, Collection Methodology, and Information Management

5(a) Agency Activities

The EPA conducts the following activities in connection with the acquisition, analysis, storage, and distribution of the required information.

Agency Activities Observe initial performance tests and re peat performance tests if necessary. Conduct on-site inspec tions as necessary. Review notifications and reports , including performance test reports, excess emissions reports, flare management plans, and requests for site-spe cific process heater emissions limits required to be submitted by industry. Audit facility records. Input, analyze, and maintain data in the AI RS (Aerometric Information Retrieval System) Facility Subsystem (AFS) database.

5(b) Collection Methodology and Management

Following notification of startup, the review ing authority might inspect the source to check if the pollution control devices are proper ly installed and operate d. Performance test7 reports are used by the Agency to discern a so urce’s initial capability to comply with the emission standard. Data obtaine d during periodic visits by Agen cy personnel from records maintained by the respondents are tabulated and published for internal Agency use in compliance and enforcement programs. The semiannual report s 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 AFS, which is operated and maintained by EPA’s Office of Air Quality Planning and Standards. AFS is EPA’s database for the collection, maintenance, and retrieval of compliance and annua l emission inventory data for over 100,000 industrial and government-owned facilities. The EPA uses AFS for tracking air pollution compliance and enforcement by State a nd local regulatory agencies, EPA Regional Offices and EPA Headquarters. The EPA and its de legated Authorities can edit, store, retrieve and analyze the data.

The records required by this NSPS must be retained by the owner or operator for two
years.
5(c) Small Entity Flexibility

A majority of the affected facilities 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. The recordkeep ing and reporting requirements were selected within the context of subpart Ja and the specific proce ss equipment and pollutants. Due to technical considerations involvi ng the process operati ons and the types of control equipment employed, the recordkeeping and reporting requirements are the same for both small and large entities. The EPA considers these requirements the minimum needed to ensure compliance and, therefore, cannot reduce them furt her for small entities. To the ex tent that larger businesses can use economies of scale to reduce their bur den, the overall burden will be reduced.

5(d) Collection Schedule

The specific frequency for each information co llection activity within this request is shown on Table 2: Industry Bu rden from Recordkeeping and Reporting – NSPS Subpart Ja.

6. Estimating the Burden and Cost of the Collection

Table 2 documents the computation of indi vidual burdens for the recordkeeping and reporting requirements applicable to the industr y for the subpart included in this ICR. The individual burdens are expressed un der standardized headings believ ed to be consis tent with the concept of burden under the Paperwork Reductio n 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, a nd a person is not required to respond to, a collection of information unless it displays a currently valid OM B control number.8 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 54,572 (Total Labor Hours from Table 2). These hours are based on Agency studies and backgrou nd documents from the development of the standards, Agency knowledge and experience wi th the NSPS program, the previously approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs
This ICR uses a Technical Labor Rate of $90.12 (composite rate of $42.92 + 110% overhead) per hour. This rate is from the United States Department of Labor, Bureau of Labor Statistics, Occupational Employment Statistics: May 2006 Employment and Wage Estimates . The rate is a weighted average of the mean wage rates for Standard Occupational Classification (SOC) Codes for Environmental Engineer s (SOC 17-2081, $38.29 per hour, 89 percent of composite), General and Operations Mana gers (SOC 11-1021, $57.58 per hour, 7 percent of composite), and Office and Administrative Support Occupations (SOC 43-0000, $17.46 per hour, 4 percent of composite) for NAICS 324 (Petroleum and Coal Products Manufacturing). The composite wage rate has been increased by 110 percent to account fo r the benefit packages available to those empl oyed by private industry.

(ii) Estimating Capital and Oper ations and Maintenance Costs

The type of industry costs associated with the information coll ection activity in the regulations are labor and continuous monitori ng. The capital/startup co sts are one-time costs when a facility becomes subject to the standa rds. The annual operation and maintenance costs are the ongoing costs to maintain the monitor and other costs such as photocopying and postage. The capital costs and the operati on and maintenance costs for th is ICR are only the additional costs associated with the required CMS for affect ed flares; the CEMS costs for other affected facilities, including process heat ers, were included in the pr eviously approved ICR for this subpart.

(iii) Capital/Start-up vs. Opera ting and Maintenance (O&M) Costs

The capital costs of the addi tional required CMS for sulfur content and flow rate are estimated to be $300,000 per flare ($43,000 annualized cap ital cost). Only 70 percent of the total affected flares are expected to be required to install CMS; the other 30 percent are expected to use the monitoring alternative for emergency flares and flares with flare gas recovery systems. This assumption results in an estimate of 262 additional flares subject to the monitoring requirements of subpart Ja over three years, or 87.3 additional flares per year. The total annualized capital cost for CMS for 262 flares is $11,266,000 per year. There are no other capital costs associated with this info rmation collection. Capital/star tup costs are shown in block 11, Hour and Cost Burden, on Part II of the Paperwork Reduction Act Submission Worksheet.9 The total operation and ma intenance (O&M) costs for this ICR are $8,750,000. This is based on an annual operating cost of $50,000 per year per flare. The total number of affected flares in the second year, 175, was used as an approximation for the average number of affected flares over three years. These costs are shown in block 11, Hour and Cost Burden, on Part II of the Paperwork Reduction Act Submission Worksheet.

The total respondent non-labor co sts in block 11 have been ca lculated as the addition of the capital/startup costs, and th e annual operation and maintena nce costs. The average annual cost for capital/startup, and operati on and maintenance costs to indus try over the next three years of the ICR is estimated to be $20,016,000. This co st is shown on Part II of the Paperwork Reduction Act Submission Worksheet in block 11, Hour and Cost Burden.

6(c) Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with anal ysis of the reported information. Publication and di stribution of the information are part of the AFS program. Examination of records to be maintained by the respondents will occur as part of the periodic inspection of sources, which is part of EPA’ s overall compliance and enforcement program.

The average annual Agency cost during the 3 ye ars of this ICR is estimated to be $84,508 (see Table 1: Average Annual EPA Resource Requirements Resulting From NSPS Subpart Ja). This cost is based on the average hourly labor rate at a GS-12, Step 1 ($26.53), times a 1.6 benefits multiplication factor to account for gove rnment overhead expenses for a total of $42.45. These rates are from OPM’s “2006 General Sc hedule” which excludes locality rates of pay. Details upon which this estimate is based appear in Table 1. This cost is in addition to the $67,085 average annual Agency cost for the previous ICR.

6(d) Estimating the Respondent Un iverse and Total Burden and Costs

Respondent Universe

Regulation

Citation (A) No. of New Sources/

Year (B) No. of Initial Reports for New Sources a (C) No. of Annual Reports for New Sources (D) No. of Existing Sources (E) No. of Reports for

Existing Sources (F) Total Annual Responses (A×(B+C))

+ (D×E) First year after proposal 44 10.7 2 0 2 557

Second year after proposal 44 10.7 2 44 2 645

Third year after proposal 44 10.7 2 88 2 733

a Initial reports are those listed in Section 3E of Table 2.

Assuming that 44 plants become subject each year, the number of total respondents in the second year is 88. This number is the sum of Co lumn A and Column D of the second row in the10 Respondent Universe table above. The number re presents the number of existing sources ( i.e.
, refineries) plus the number of new sources averag ed over the three-year period. It is shown in block 9, Respondents, on Part II of the Paperwork Reduction Act Submission Worksheet.

The number of Total Annual Res ponses in the second year is 645. This is the number in Column F of the second row in the Respondent Un iverse table. It is shown in block 10, Annual Number of Responses, on Part II of the Pape rwork Reduction Act Submission Worksheet. The total annual labor costs are $$4,918,110. The number of burden hours on which this estimate is based, 54,572, is shown on Part II of the Pa perwork Reduction Act Submission Worksheet on block 11, Hour and Cost Burden. Details upon which this estimate is base d appear in Table 2: Annual burden of reporting and recordkeeping re quirements as a result of NSPS subpart Ja.

The total annualized capital and annual O&M costs to the regulated entity are $20,016,000. This number is shown in block 11, Hour and Cost Burden, on Part II of the Paperwork Reduction Act Submission Worksheet. Thes e costs are detailed in section 6(b)(iii), Capital/Start-up vs. Operating a nd Maintenance (O&M) Costs.

6(e) Bottom Line Burden Hours And Cost Tables

The bottom line burden hours and cost tables for both the Agency and the respondents are attached.

6(f) Reasons for Change in Burden

As previously noted, the EPA originally estim ated that 18 plants (including 18 flares) would become subject to 40 CFR part 60, subpart Ja. However, the EPA now estimates that a total of 400 flares at 150 refineries will become subject to 40 CFR part 60, subpart Ja over the first three years. The burden presented in this ICR is fo r recordkeeping and reporting requirements associated with the additional 382 fl ares at 132 additional re fineries that the EPA projects will become subject to 40 CFR part 60, subpart Ja. This burden has not been estimated in a previous ICR.

6(g) Burden Statement

Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or di sclose or provide information to or for a Federal agency. This includes the time needed to revi ew instructions; develop, acquire , install, and utilize technology and systems for the purposes of collecting, valid ating, and verifying information, processing and maintaining information, and disclosing and providi ng information; adjust the existing ways to comply with any previously applicable instructio ns and requirements; train personnel to be able to respond to a collection of info rmation; search data sources; co mplete and review the collection of information; and transmit or otherwise disc lose the information. An agency may not conduct or sponsor, and a person is not required to re spond to, a collection of information unless it displays a currently valid OMB control num ber. The OMB control numbers for EPA’s regulations are listed in 40 CF R Part 9 and 48 CFR Chapter 15.11 Send comments on the Agency’s need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including through the use of automated co llection techniques to the Di rector, Collection Strategies Division (Mail Code 2822T), Offi ce of Environmental Information, United States Environmental Protection Agency, 1200 Pennsylvania Avenue, N.W., Washington, D.C. 20460-0001; and to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, N.W., Washington, DC 2050, Attention: Desk Officer for EPA. Include the EPA ICR number and OMB control number in any correspondence.

Part B of the Supporting Statement

This part is not applicable because no stat istical methods were used in collecting this information.12TABLE 1: AVERAGE ANNUAL EPARESOURCE REQUIREMENTS FORADDITIONAL AFFECTED FLARESSUBJECT TO NSPS SUBPART JaActivityEPA hours/Occurrence(A)Occurrences/plant/year(B)aEPA hours/plant/year(C = A × B)Plants/year(D)EPA hours/ year(E = C × D)New Plants:Report ReviewNotification of construction,reconstruction, or modification 2 2.89 5.79 44 254.67Notification of anticipated startup 0.5 2.89 1.45 44 63.67Notification of actual startup 0.5 2.89 1.45 44 63.67Notification of accuracy test 0.5 1.98 0.99 44 43.67Flare management plansb1 2.89 2.89 44 127.33Review test results 8 1.98 15.88 44 698.67Emission Reports 4.2 2 8.4 44 369.6Existing Plants:Emission Reports 4.2 2 8.4 44 369.6TOTAL ANNUAL HOURS 1,991Salary:c(1,991 hours/year × $42.45/hour) = $84,508/yearTOTAL ANNUAL COST = $84,508aAssume 2.89 flares per refinery (382 flares at 132 refineries), 1.98 of which (262 flares at 132 refineries) would be requiredto install monitors for sulfur contentand flow rate. Assume each refinery submits two emission reports per year, regardless of the number of affected flares.bSome plans will need more review than others, depending on complexity of flare connections and baseline calculations; assume 1hour is the average amount oftime spent per plan.cEstimate an hourly wage of $26.53 plus 60 percent overhead expense which equals $42.45.13TABLE 2: INDUSTRY BURDENFROM RECORDKEEPING AND REPORTING FOR ADDITIONAL AFFECTEDFLARES – NSPS SUBPART JaaHours perOccurrence(A)Occurrences/respondent/ year(B)bHours/respondent/ year(C = A × B)Responses peryear(D)Total LaborHours per year(E = C × D)Cost per yearc(F)1. APPLICATIONS _____________________________________Not Applicable_____________________________________2. SURVEY AND STUDIESA. Flare Management Plan160 2.89 463.03 44 20,373.33 $1,836,075.36B. Root Cause Analysis (flow)45 4 180 88 15,840 $1,427,524.56C. Root Cause Analysis (sulfur)24 3 72 88 6,336 $571,009.823. REPORTING REQUIREMENTSA. Read Instructions1 1 1 44 44 $3,965.35B. Required ActivitiesInitial Relative Accuracy Testd24 3.97 95.27 44 209.6e$18,889.47CMS Audits (RAA or CGA)d36 3.97 142.91 44 314.4e$28,334.20C. Create InformationIncluded in 3BD. Gather Existing InformationIncluded in 3EE. Write ReportNotification of construction,reconstruction, ormodification2 2.89 5.79 44 254.67 $22,950.94Notification of anticipatedstartup2 2.89 5.79 44 254.67 $22,950.94Notification of actual startup 2 2.89 5.79 44 254.67 $22,950.94Notification of initialperformance test2 1.98 3.97 44 174.67 $15,741.22Report of performance test Included in 3BSemiannual Emission Reports 16 2 32 88 2,816 $253,782.1414Hours perOccurrence(A)Occurrences/respondent/ year(B)bHours/respondent/ year(C = A × B)Responses peryear(D)Total LaborHours per year(E = C × D)Cost per yearc(F)4. RECORDKEEPINGREQUIREMENTSA. Read InstructionsIncluded in 3AB. Plan ActivitiesIncluded in 3BC. Implement ActivitiesIncluded in 3BD. Develop Record System_____________________________________Not Applicable_____________________________________E. Time to Enter InformationRecords of operating parameters 0.25 350f87.5 88 7,700 $693,935.55F. Train Personnel_____________________________________Not Applicable_____________________________________G. Audits_____________________________________Not Applicable_____________________________________5. TOTAL ANNUAL BURDEN 54,572 $4,918,110.506. CAPITAL/O&M COSTSAnnualized Total Capital Cost $11,266,000Annual O&M Cost $8,750,000Total Annualized Capital andAnnual O&M Cost$20,016,000aAssume that there are approximately 132 plants (respondents) which become subject over a 3-year period. The number of new sources per year equals 44. In thesecond year, assume the number of existing sources (i.e., sources becoming subject to the rule in the first year) is 44 and the number of new sources is 44. Alsoassume there are approximately 2.89flares per refinery (382 flares at 132 refineries), 1.98 of which (262 flares at 132 refineries) would require sulfur contentand flow rate monitors.bOccurrences per respondent per year is calculated as the number of occurrences per flare per year multiplied by the number offlares per respondent (refinery).cAssume an hourly wage of $42.92 plus 110 percent overhead costs which equals $90.12. This amount was multiplied by the hours per year in Column E.dAssume that there are two monitors needed for each flare, one tomonitor sulfur content and one to monitor flow rate.ePerson-hours and annual costare estimated to be 5 percent of the time that a CMS is in operation (E= .05C×D).fAssume operation 350 days per year asspecified in the NSPS review document.