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 Petroleum 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 process heaters that are 

constructed, reconstructed, or modified after May 14, 2007 and flares that are constructed, 

reconstructed, or modified after June 24, 2008. Emissions limitations, which include hydrogen 

sulfide (H2S) concentration limits, will be used to control emissions of nitrogen oxides (NOX) 

and sulfur dioxide (SO2). Other standards will apply to flaring of fuel gases, which will reduce 

emissions of NOX, SO2, carbon monoxide (CO), and volatile organic compounds (VOC). These 

standards will require plants to conduct an analysis of any exceedance or discharge of SO2

emissions that exceeds 500 pounds in 24 hours or a discharge to a flare exceeding 500,000 

standard cubic feet in 24 hours above the baseline flow to the flare. Plants will be required to 

monitor the sulfur content and the flow to an affected flare to determine if they exceed these 

thresholds. Plants will also be required to prepare written plans to describe the flare, identify the 

process units connected to the flare, and describe methods to minimize emissions from planned 

startup and shutdown of process units. 

Plants will be required to use continuous monitoring systems (CMS) or continuous 

emissions monitoring systems (CEMS), depending on the type and size of unit, pollutant, and 

control device. Alternative monitoring options are included for small process heaters and fuel 

gases with intrinsically low H2S concentrations. In general, all NSPS recordkeeping and 

reporting requirements for initial notifications, performance test reports, reports of performance 

evaluations, and periodic reports of excess emissions 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 burden for affected sources at 18 plants, including process units 

and flares. This ICR estimates burden for 382 additional flares expected to become affected 

facilities at 132 additional refineries over the first three years (for a total of 400 affected flares at 

150 refineries over the first three years). 
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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 into 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 selecting the best demonstrated technology. Section 

111 also requires that the Administrator review and, if appropriate, revise such standards every 

eight years. In the Administrator’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 public 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 standards are being revised. 

2(b) Practical Utility/Users of the Data 

The required notifications are used to inform the Agency or delegated authority when a 

source becomes subject to the standard. The reviewing 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 with 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 for this information from quarterly to 

semiannually. The information generated by the monitoring, recordkeeping and reporting 

requirements described in this ICR is used by the Agency to ensure that facilities affected by the 

NSPS continue to operate the control equipment and achieve compliance with the standards. 

Adequate monitoring, recordkeeping, and reporting are necessary to ensure compliance with the 

applicable regulations, as required by the Clean 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 required for sources subject to 40 CFR part 

60, subpart Ja. Existing refineries that are major sources of hazardous air pollutants are subject to 

maximum achievable control technology (MACT) standards under 40 CFR part 63 subparts CC 

and UUU for the control of hazardous air pollutants. Many refineries will also have existing 
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sources that are subject to the emission limitations and associated monitoring, recordkeeping, 

and reporting requirements for criteria pollutants in 40 CFR part 60, subpart J. 

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. 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 management plan sent to the EPA 

Regional Office or State or local agency. If a State or local agency has adopted their 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. 

3(b) Public Notice Required Prior 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 period after proposal of the amendments to 

NSPS subpart Ja. All affected parties were given 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 developing the final standards. 

During development of the proposed and promulgated standards, the EPA held meetings 

and conference calls with representatives of petroleum refining companies and their trade 

associations (National Petrochemicals and Refiners Association and American Petroleum 

Institute). While these meetings were generally focused on the standards for process heaters and 

flares, alternative monitoring, recordkeeping, and reporting requirements for certain types of 

flares were discussed, and an alternative water seal monitoring approach was developed that 

reduces the burden estimates associated with monitoring 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 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 likelihood of detecting poor operation and maintenance of control 

equipment and noncompliance would decrease. 
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3(e) General Guidelines 

None of the reporting or recordkeeping requirements contained in 40 CFR part 60, 

subpart Ja or otherwise pertinent 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 safeguarded according to the Agency policies set forth in 

Title 40, Chapter 1, Part 2, Subpart B – Confidentiality 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 this request contain sensitive questions. 

4. The Respondents and the Information Requested 

4(a) Respondents/SIC Codes 

The respondents of the recordkeeping and reporting requirements in this ICR are affected 

flares at petroleum refineries which commence construction, modification, or reconstruction after 

June 24, 2008. The SIC code for the respondents affected by the standards is SIC (U.S. Standard 

Industrial Classification) 2911 which corresponds 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: 
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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 performance 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 analyses 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. 
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Respondent Activities 

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. 

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. 

Transmit, or otherwise disclose the information. 

Continuous monitoring system (CMS) information 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 responses 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 repeat performance tests if necessary. 

Conduct on-site inspections as necessary. 

Review notifications and reports, including performance test reports, excess emissions reports, 

flare management plans, and requests for site-specific process heater emissions limits required 

to be submitted by industry. 

Audit facility records. 

Input, analyze, and maintain data in the AIRS (Aerometric Information Retrieval System) 

Facility Subsystem (AFS) database. 

5(b) Collection Methodology and Management 

Following notification of startup, the reviewing authority might inspect the source to 

check if the pollution control devices are properly installed and operated. Performance test 
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reports are used by the Agency to discern a source’s initial capability to comply with the 

emission standard. Data obtained during periodic visits by Agency personnel from records 

maintained by the respondents are tabulated and published for internal Agency 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 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 annual 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 and local regulatory agencies, EPA Regional 

Offices and EPA Headquarters. The EPA and its delegated 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 recordkeeping and reporting requirements were selected 

within the context of subpart Ja and the specific process equipment and pollutants. Due to 

technical considerations involving the process operations 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 further for small entities. To the extent that larger businesses can 

use economies of scale to reduce their burden, the overall burden will be reduced. 

5(d) Collection Schedule 

The specific frequency for each information collection activity within this request is 

shown on Table 2: Industry Burden from Recordkeeping and Reporting – NSPS Subpart Ja. 

6. Estimating the Burden and Cost of the Collection 

Table 2 documents the computation of individual burdens for the recordkeeping and 

reporting requirements applicable to the industry for the subpart 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. 
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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 background documents from the development of the 

standards, Agency knowledge and experience with 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 Engineers (SOC 17-2081, $38.29 per hour, 89 percent of 

composite), General and Operations Managers (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 for the benefit packages 

available to those employed by private industry. 

(ii) Estimating Capital and Operations and Maintenance Costs 

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

regulations are labor and continuous monitoring. The capital/startup costs are one-time costs 

when a facility becomes subject to the standards. 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 operation and maintenance costs for this ICR are only the additional 

costs associated with the required CMS for affected flares; the CEMS costs for other affected 

facilities, including process heaters, were included in the previously approved ICR for this 

subpart. 

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

The capital costs of the additional required CMS for sulfur content and flow rate are 

estimated to be $300,000 per flare ($43,000 annualized capital 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 information collection. Capital/startup costs are shown in block 11, 

Hour and Cost Burden, on Part II of the Paperwork Reduction Act Submission Worksheet. 
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The total operation and maintenance (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 costs in block 11 have been calculated as the addition of 

the capital/startup costs, and the annual operation and maintenance costs. The average annual 

cost for capital/startup, and operation and maintenance costs to industry over the next three years 

of the ICR is estimated to be $20,016,000. This cost 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 analysis of the reported 

information. Publication and distribution 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 years 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 government overhead expenses for a total of $42.45. 

These rates are from OPM’s “2006 General Schedule” 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 Universe and Total Burden and Costs 

Respondent Universe 

Regulation 

Citation 

(A) No. of 

New 

Sources/ 

Year 

(B) No. of 

Initial 

Reports for 

New 

Sourcesa

(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 Column A and Column D of the second row in the 
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Respondent Universe table above. The number represents the number of existing sources (i.e., 

refineries) plus the number of new sources averaged 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 Responses in the second year is 645. This is the number in 

Column F of the second row in the Respondent Universe table. It is shown in block 10, Annual 

Number of Responses, on Part II of the Paperwork 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 Paperwork Reduction Act Submission Worksheet on 

block 11, Hour and Cost Burden. Details upon which this estimate is based appear in Table 2: 

Annual burden of reporting and recordkeeping requirements 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. These costs are detailed in section 6(b)(iii), 

Capital/Start-up vs. Operating and 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 estimated 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 for recordkeeping and reporting 

requirements associated with the additional 382 flares at 132 additional refineries 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 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 currently valid OMB control number. The OMB control numbers for EPA’s 

regulations are listed in 40 CFR Part 9 and 48 CFR Chapter 15. 
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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 collection techniques to the Director, Collection Strategies 

Division (Mail Code 2822T), Office 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 statistical methods were used in collecting this 

information. 
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TABLE 1: AVERAGE ANNUAL EPA RESOURCE REQUIREMENTS FOR ADDITIONAL AFFEC

SUBJECT TO NSPS SUBPART Ja 

Activity 

EPA hours/ 

Occurrence 

(A) 

Occurrences/ 

plant/year 

(B)a

EPA hours/ 

plant/year 

(C = A × B) 

Plants/year

(D) 

New Plants: 

Report Review 

Notification of construction, reconstruction, or modification 2 2.89 5.79 44 

Notification of anticipated startup 0.5 2.89 1.45 44 Notification of actual startup 0.5 2.89 1.45 44 Notification of accuracy test 0.5 1.98 0.99 44 Flare management plansb 1 2.89 2.89 44 

Review test results 8 1.98 15.88 44 Emission Reports 4.2 2 8.4 44 

Existing Plants: 

Emission Reports 4.2 2 8.4 44 

TOTAL ANNUAL HOURS Salary:c(1,991 hours/year × $42.45/hour) = $84,508/year TOTAL ANNUAL COST = $84,508a Assume 2.89 flares per refinery (382 flares at 132 refineries), 1.98 of which (262 flares at 132 refineries) would be required to install m

and flow rate. Assume each refinery submits two emission reports per year, regardless of the number of affected flares. 

b Some plans will need more review than others, depending on complexity of flare connections and baseline calculations; assume 1 hou

time spent per plan. 

c Estimate an hourly wage of $26.53 plus 60 percent overhead expense which equals $42.45. 
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TABLE 2: INDUSTRY BURDEN FROM RECORDKEEPING AND REPORTING FOR ADDITION

FLARES – NSPS SUBPART Jaa

Hours per 

Occurrence 

(A) 

Occurrences/ 

respondent/ year 

(B)b

Hours/ 

respondent/ year 

(C = A × B) 

Responses per 

year 

(D) 

Total Labo

Hours per ye

(E = C × D

1. APPLICATIONS _____________________________________Not Applicable______________________2. SURVEY AND STUDIES 

A. Flare Management Plan 160 2.89 463.03 44 20,373.33 B. Root Cause Analysis (flow) 45 4 180 88 15,840 C. Root Cause Analysis (sulfur) 24 3 72 88 6,336 

3. REPORTING REQUIREMENTS 

A. Read Instructions 1 1 1 44 44 B. Required Activities

Initial Relative Accuracy Testd 24 3.97 95.27 44 209.6e CMS Audits (RAA or CGA)d 36 3.97 142.91 44 314.4e 

C. Create Information Included in 3B D. Gather Existing Information Included in 3E E. Write Report

Notification of construction, 

reconstruction, or modification 

2 2.89 5.79 44 254.67 

Notification of anticipated 

startup 2 2.89 5.79 44 254.67 

Notification of actual startup 2 2.89 5.79 44 254.67 Notification of initial 

performance test 2 1.98 3.97 44 174.67 

Report of performance test Included in 3B Semiannual Emission Reports 16 2 32 88 2,816 
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Hours per 

Occurrence 

(A) 

Occurrences/ 

respondent/ year 

(B)b

Hours/ 

respondent/ year 

(C = A × B) 

Responses per 

year 

(D) 

Total Labo

Hours per ye

(E = C × D

4. RECORDKEEPING REQUIREMENTS 

A. Read Instructions Included in 3A B. Plan Activities Included in 3B C. Implement Activities Included in 3B D. Develop Record System _____________________________________Not Applicable______________________E. Time to Enter Information

Records of operating parameters 0.25 350f 87.5 88 7,700 

F. Train Personnel _____________________________________Not Applicable______________________G. Audits _____________________________________Not Applicable______________________

5. TOTAL ANNUAL BURDEN 54,572 6. CAPITAL/O&M COSTS 

Annualized Total Capital Cost Annual O&M Cost Total Annualized Capital and 

Annual O&M Cost 

a Assume that there are approximately 132 plants (respondents) which become subject over a 3-year period. The number of new source

second year, assume the number of existing sources (i.e., sources becoming subject to the rule in the first year) is 44 and the number assume there are approximately 2.89 flares per refinery (382 flares at 132 refineries), 1.98 of which (262 flares at 132 refineries) wouand flow rate monitors. 

b Occurrences per respondent per year is calculated as the number of occurrences per flare per year multiplied by the number of flares pc Assume an hourly wage of $42.92 plus 110 percent overhead costs which equals $90.12. This amount was multiplied by the hours per d Assume that there are two monitors needed for each flare, one to monitor sulfur content and one to monitor flow rate. e Person-hours and annual cost are estimated to be 5 percent of the time that a CMS is in operation (E= .05C×D). f Assume operation 350 days per year as specified in the NSPS review document.