SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NSPS for Petroleum Refineries (40 CFR Part 60, Subpart Ja) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NSPS for Petroleum Refineries (40 CFR Part 60, Subpart Ja) (Renewal), EPA ICR Number 

2263.03, OMB Control Number 2060-0602

1(b) Short Characterization/Abstract

The New Source Performance Standards (NSPS) for the regulations published at 40 CFR 

part 60, subpart Ja, apply to affected facilities that are constructed, reconstructed, or modified after 

May 14, 2007. The affected facilities include: fluid catalytic cracking units, fluid coking units, 

delayed coking units, process heaters and other fuel gas combustion devices, and sulfur recovery

plants. Emissions limitations would be used to control emissions of particulate matter (PM), 

nitrogen oxides (NOx), carbon monoxide (CO), sulfur dioxide (SO2), hydrogen sulfide (H2S) 

and/or reduced sulfur compounds (RSC). Work practice standards would apply to depressuring 

operations and flaring of fuel gases. Plants would also conduct an analysis of any exceedance or 

discharge of SO2 emissions that exceeds 500 pounds per day. Plants would be required to prepare 

written plans to describe monitoring for the flow to an affected flare, methods to minimize 

emissions from planned startup and shutdown of process units, and procedures for investigating 

the causes of large flaring events.

Owners or operators of the affected facilities would be required to use continuous 

parameter monitoring systems (CPMS), bag leak detection systems, or continuous emissions 

monitoring systems (CEMS), depending on the type of unit, pollutant, and control device. 

Exemptions are included for low emitters of CO or H2S. An initial performance test would be 

required for all affected facilities; some affected facilities using CPMS would be required to 

conduct more frequent tests. 

Owners or operators of the affected facilities described must make the following 

one-time-only reports: notification of the date of construction or reconstruction; notification of the 

actual dates of startup; notification of any physical or operational change to an existing facility

which may increase the regulated pollutant emission rate; notification of the date of the initial 

performance test; and the results of the initial performance test. In general, these notifications, 

reports and records are required of all sources subject to NSPS.

In general, any owner or operator subject to the provisions of this part will maintain a file 

of these records, and retain the file for at least two years following the date of such measurements, 

maintenance reports, and records. Records of all replacements or additions of components shall be 

kept on file for at least three years. The reporting requirements for this industry currently include 

only the initial notifications and initial performance test report listed above. All reports are sent to 

the delegated state or local authority. In the event that there is no such delegated authority, the 
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reports are sent directly to the United States Environmental Protection Agency (EPA) regional 

office.

Approximately 18 sources are currently subject to the regulation, (i.e., bulk terminals with 

a gasoline throughput greater than 75,700 liters/day). It is estimated that no additional respondents 

per year will become subject to the regulation in the next three years.

In the United States, there are approximately18 petroleum refineries facilities which are 

owned and operated by the bulk gasoline terminals industry (the “Affected Public”). These

facilities are privately owned for-profit businesses, and are not owned by state, local, tribal, or the 

Federal government,. The burden to the “Affected Public” is listed in Table 1: Annual Industry

Burden and Cost – NSPS for Petroleum Refineries (40 CFR Part 60, Subpart Ja) (Renewal). The 

Federal government burden associated with the review of reports submitted by the respondent is 

shown in Table 2: Average Annual EPA Burden – NSPS Petroleum Refineries (40 CFR Part 60, 

Subpart Ja) (Renewal).

The Office of Management and Budget (OMB) approved the currently active Information 

Collection Request (ICR) without any “Terms of Clearance (TOC).” 

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 (BDT). Section 

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

four years. 

In addition, section 114(a) states that the Administrator may require any owner or 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 
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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.

In the Administrator's judgment, CEMS emissions from petroleum refineries cause or 

contribute to air pollution that may reasonably be anticipated to endanger public health or welfare. 

Therefore, the NSPS was promulgated for this source category at 40 CFR part 60, subpart Ja.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensure compliance with the 

applicable regulations which were promulgated in accordance with the Clean Air Act. In addition, 

the collected information is 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 standard. Continuous emission monitors are used to ensure 

compliance with the standard at all times. During the performance tests, 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 standard 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 ensure that the pollution control devices are properly 

installed and operated, that leaks are being detected and repaired, and that the standards are being 

met. The performance test may also be observed.

The required semiannual reports are used to determine periods of excess emissions, to 

identify problems at the facility, to verify operation/maintenance procedures and compliance.

3. Non-duplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR part 60, subpart Ja.

3(a) Non-duplication

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 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

An announcement of a public comment period for the renewal of this ICR was published in 
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the Federal Register (76 FR 26900) on May 9, 2011. No comments were received on the burden 

published in the Federal Register.

3(c) Consultations

The Agency’s industry experts have been consulted, and the Agency’s internal data 

sources and projections of industry growth over the next three years have been considered. The 

primary source of information as reported by industry, in compliance with the recordkeeping and 

reporting provisions in the standard, is the Online Tracking Information System (OTIS) which is 

operated and maintained by the EPA Office of Compliance. OTIS is the EPA database for the 

collection, maintenance, and retrieval of all compliance data. The growth rate for the industry is 

based on our consultations with the Agency’s internal industry experts.

Industry trade associations and other interested parties were provided an opportunity to 

comment on the burden associated with the standard as it was being developed. In developing this 

ICR, we contacted the American Petroleum Institute (API) at (202) 682-8319, the Oil Price 

Information Services (OPIS) at (877) 210-4287, and the Service Station Dealers of America/

National Coalition of Petroleum Retailers and Allied Trades (SSDA/NCPR) at (301) 390-4405.

It is our policy to respond after a thorough review of comments received since the last ICR 

renewal as well as those submitted in response to the first Federal Register notice.

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 the 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 the EPA to establish the compliance history of a 

source, any pattern of non-compliance, and to determine the appropriate level of enforcement 

action. EPA has found that the most flagrant violators have violations extending beyond the five 

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

nonexistence of essential records.
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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 bulk gasoline 

terminals. The United States Standard Industrial Classification (SIC) code for the respondents 

affected by the standards is SIC 2911 which corresponds to the North American Industry

Classification System (NAICS) 324110 for petroleum refineries.

4(b) Information Requested

None of these reporting or recordkeeping requirements violate any of the regulations 

established by OMB at 5 CFR part 1320, section 1320.5.

(i) Data Items

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

Refineries (40 CFR Part 60, Subpart Ja) (Renewal).

A source must make the following reports:

Notifications

Construction/reconstruction 60.7(a)(1) 

Initial notifications 60.7 

Actual Start-up 60.7(a)(3) 

Excess emissions report 60.7(c), 60.108a(f) 

Initial performance test results 60.8(a) 

Notification of initial performance test 60.8(d) 

Demonstration of continuous emission monitoring system (CEMS) 60.7(a)(5) 

Notification of Compliance status 60.11(a-c) 

Physical or Operational Change 60.7(a)(4) 

Periodic start-up, shutdown, malfunction reports 60.8(c) 

Written work practice plans/root cause analysis 60.103a(a-b)
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A source must keep the following records:

Recordkeeping 

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, bag leak detection system alarms, records of 

coke burn-off rate, monitoring exemptions, discharges to flare gas 

system

60.108a

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.

Also, regulatory agencies in cooperation with the respondents continue to create reporting 

systems to transmit data electronically. However, electronic reporting systems are not widely 

used. At this time, it is estimated that approximately 70 percent of the respondents use electronic 

reporting.

Respondent Activities

Read instructions.

Gather relevant information.

Install, calibrate, maintain, and operate CEMS for opacity, or for pressure drop and liquid 

supply pressure for wet scrubber

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.

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.

Currently, sources are using monitoring equipment that provides parameter data in an 

automated way (e.g., continuous parameter monitoring system). Although personnel at the source 
7

still need to evaluate the data, this type of monitoring equipment has significantly reduced the 

burden associated with monitoring and recordkeeping.

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

Observe initial performance tests and repeat performance tests if necessary.

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

required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the Online Tracking Information system (OTIS).

5(b) Collection Methodology and Management

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

determine whether the pollution control devices are properly installed and operational. Performance 

test reports are used by the Agency to discern a source’s initial capability to comply with the 

emission standard, and to note the operating conditions under which compliance was achieved. 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 OTIS which is operated and maintained 

by the EPA Office of Compliance. OTIS is the EPA database for the collection, maintenance, and 

retrieval of compliance data for approximately 125,000 industrial and government-owned 

facilities. EPA uses OTIS for tracking air pollution compliance and enforcement by local and state 

regulatory agencies, EPA regional offices, and EPA headquarters. EPA 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 two 

years.

5(c) Small Entity Flexibility

The 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. 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 Agency considers these to be the minimum 
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requirements 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 

in Table 1: Annual Industry Burden for NSPS for NSPS for Petroleum Refineries (40 CFR Part 60, 

Subpart Ja) (Renewal).

6. Estimating the Burden and Cost of the Collection

Table 1 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. Wherever 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 2,142 (Total Labor Hours from Table 1). These 

hours are based on Agency studies and background documents from the development of the 

regulation, 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 the following labor rates:

Managerial $119.36 ($56.84 + 110%) 

Technical $99.18 ($47.23 + 110%)

Clerical $49.35 ($23.50 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 

2011, "Table 2. Civilian Workers, by Occupational and Industry group." The rates are from 

column 1, "Total Compensation." The rates have been increased by 110 percent to account for the 

benefit packages available to those employed by private industry.

(ii) Estimating Capital/Startup and Operation and Maintenance Costs
9

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

subject standard 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. The annual operation and maintenance costs are the 

ongoing costs to maintain the monitor and other costs, such as photocopying and postage.

(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 

Respondent

(C)

Number of 

New

Respondents 1

(D)

Total 

Capital/Startup 

Cost 

(B X C) 

(E)

Annual O&M 

Costs for One 

Respondent

(F)

Number of 

Respondents 

with O&M 1

(G)

Total 

O&M,

(E X F) 

CEMS $19,000 0 $0 $15,520 18 $1,676,160

Total $0 $1,676,160

1 This is based on 6 CEMS per respondent

The total capital/startup costs for this ICR are $0. This is the total of column D in the above 

table.

The total operation and maintenance (O&M) costs for this ICR are $1,676,160. This is the 

total of column G.

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 $1,676,160

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 

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 

$7,836.

This cost is based on the average hourly labor rate as follows:

Managerial $62.27 (GS-13, Step 5, $38.92 + 60%) 

Technical $46.21 (GS-12, Step 1, $28.88 + 60%)

Clerical $25.01 (GS-6, Step 3, $15.63 + 60%)

These rates are from the Office of Personnel Management (OPM) “2011 General Schedule” which 

excludes locality rates of pay. The rates have been increased by 60 percent to account for the 

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

appear in Table 2: Average Annual EPA Burden, NSPS for Petroleum Refineries (40 CFR Part 60, 
10

Subpart Ja) (Renewal).

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 18

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

per year will become subject to the standard. The overall average number of respondents, as 

shown in the table below, is 18 per year. 

The number of respondents is calculated using the following table that addresses the three 

years covered by this ICR.

Number of Respondents

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 0 18 0 0 18

2 0 18 0 0 18

3 0 18 0 0 18

Average 0 18 0 0 18

1 New respondents include sources with constructed, reconstructed, and modified affected facilities.

To avoid double-counting respondents, column D is subtracted. As shown above, the 

average Number of Respondents over the three-year period of this ICR is 18.

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

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

Initial of construction/reconstruction 0 0 0 0

Notification of anticipated startup 0 0 0 0

Notification of actual startup 0 0 0 0

Notification of performance test 0 0 0 0

Semiannual reports of excess emission 18 2 36 36

Total 36

The number of Total Annual Responses is 36.
11

The total annual labor costs are $197,720. Details regarding these estimates may be found 

in Table 1: Annual Industry Burden and Cost – NSPS for Petroleum Refineries (40 CFR Part 60, 

Subpart Ja) (Renewal).

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 2,142. Details regarding these estimates may be found in 

Table 1: Annual Respondent Burden and Cost: NSPS for Petroleum Refineries (40 CFR Part 60, 

Subpart Ja) (Renewal).

Furthermore, the annual public reporting and recordkeeping burden for this collection of 

information is estimated to average 59 hours per response.

The total annual capital/startup and operation and maintenance (O&M) costs to the 

regulated entity is $1,676,160.

(ii) The Agency Tally

The average annual Agency burden and cost over the next three years is estimated to be 

174 labor hours at a cost of $7,836. See Table 2: Annual Agency Burden and Cost: NSPS for 

Petroleum Refineries (40 CFR Part 60, Subpart Ja) (Renewal).

6(f) Reasons for Change in Burden

There is a decrease in the labor hours and cost in this ICR compared to the previous ICR. 

Consultations with the Office of Air Quality Planning and Standards (OAQPS) and trade 

associations revealed that there are approximately eighteen sources subject to the rule, with no new 

facilities expected to be constructed over the next three years of this ICR.

Because there are no new sources with reporting requirements, no capital/startup costs are 

incurred. The only cost that is incurred is for the O&M of the monitoring equipment.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is 

estimated to average 59 hours per response. Burden means the total time, effort, or financial 

resources expended by persons to generate, maintain, retain, 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; 
12

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-2011-0228, which is available for online viewing at 

www.regulations.gov, or in person viewing at the Enforcement and Compliance Docket in the 

EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Avenue, NW, 

Washington, D.C. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 

p.m., Monday through Friday, excluding legal holidays. The telephone number for the Reading 

Room is (202) 566-1744, and the telephone number for the Enforcement and Compliance Docket

is (202) 566-1752. An electronic version of the public docket is available at www.regulations.gov. 

This site can be used to submit or view public comments, access the index listing of the contents of 

the public 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 

above. Also, you can send comments to the Office of Information and Regulatory Affairs, Office 

of Management and Budget, 725 17th Street, N.W., Washington, D.C. 20503, Attention: Desk 

Officer for EPA. Please include the EPA Docket ID Number EPA-HQ-OECA-2011-0228 and 

OMB Control Number 2060-0602 in any correspondence.

Part B of the Supporting Statement

This part is not applicable because no statistical methods were used in collecting this 

information.
Table 1: Annual Respondent Burden and Cost – NSPS for Petroleum Refineries (40 CFR Part 60, Subpart Ja) (Renewal)

Burden item

(A)

Person 

hours per 

occurrence

(B)

No. of 

occurrences 

per 

respondent 

per year

(C)

Person 

hours per 

respondent 

per year

(C=AxB)

(D)

Respondents 

per year 

a

(E)

Technical 

personhours per 

year

(E=CxD)

(F)

Management 

person hours 

per year

(Ex0.05)

(G)

Clerical 

person 

hours 

per year

(Ex0.1)

(H)

Total Cost 

Per year b

1. Applications N/A

2. Survey and Studies

 Flare management plan 160 1 160 0 0 0 0 $0

 Root cause analysis` 40 4 160 0 0 0 0 $0

3. Reporting requirements

 A. Read instructions 1 1 1 0 0 0 0 $0

 B. Required activities

 Initial performance tests c40 6 320 0 0 0 0 $0

 Repeat of performance tests d40 0.2 8 0 0 0 0 $0

 Relative accuracy test 24 6 192 0 0 0 0 $0

 CEMS audits (RAA or CGA) 36 6 288 0 0 0 0 $0

 C. Create Information

 D. Gather existing information See 3B 

 E. Write Report e

 Notification of construction/reconstruction 2 7 14 0 0 0 0 $0

 Notification of anticipated startup 2 7 14 0 0 0 0 $0

 Notification of actual startup 2 7 14 0 0 0 0 $0

 Notification of initial performance test 2 7 14 0 0 0 0 $0

 Report of performance test See 3B

 Semiannual reports of excess emission f8 2 16 18 288 14.4 28.8 $31,703.90

Subtotal for Reporting Requirements

4. Recordkeeping requirements 331.2

 A. Read instructions See 3A

 B. Plan activities See 3B

 C. Implement Activities See 3B

 D. Develop record system N/A

 E. Time to enter information

 Records of operating parameters g0.25 350 87.5 18 1,575 78.75 157.5 $166,016.60

 F. Time to train personnel N/A

 G. Time for audits N/A

Subtotal for Recordkeeping Requirements 1,811.25
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Burden item

(A)

Person 

hours per 

occurrence

(B)

No. of 

occurrences 

per 

respondent 

per year

(C)

Person 

hours per 

respondent 

per year

(C=AxB)

(D)

Respondents 

per year 

a

(E)

Technical 

personhours per 

year

(E=CxD)

(F)

Management 

person hours 

per year

(Ex0.05)

(G)

Clerical 

person 

hours 

per year

(Ex0.1)

(H)

Total Cost 

Per year b

Subtotals: Labor Burden and costs 1,863 93.15 186.3 $197,720.50

TOTAL LABOR BURDEN AND COST 

(rounded)

2,142.45

2,142

 (rounded) 

$197,720

Assumptions:

 a We have assumed that there are approximately 18 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three 

years. 

 b

 This ICR uses the following labor rates: $119.36 per hour for Executive, Administrative, and Managerial labor; $99.18 per hour for Technical labor, and $49.35 

per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2011, Table 2. Civilian Workers, by 

Occupational and Industry groups. The rates are from column 1, Total Compensation. The rates have been increased by 110 percent to account for the benefit 

packages available to those employed by private industry.

c

 We have assumed that it will take 40 hour for each respondent to perform initial performance tests. There are 6 CEM units per plant (respondent)

d

 We have assumed that 20 percent of sources would have to repeat performance test due to failure.

e

 We have assumed that each respondent will take 2 hours to write report.

f

 We have assumed that each respondent will take 8 hours twice per year to complete semiannual reports.

g

 We have assumed that it will take 0.5 hours, 350 times per year for each respondent to enter and operating parameters reports.
15

Table 2: Average Annual EPA Burden - NSPS for Petroleum Refineries (40 CFR Part 60, Subpart Ja) (Renewal)

Activity

(A)

EPA 

personhours per 

occurrence

(B)

No. of 

occurrences 

per plant 

per year

(C)

EPA 

personhours per 

plant per 

year

(C=AxB)

(D)

Plants 

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

New Plants

 Initial notification test 24 1 24 0 0 0 0 $0

 Report of performance test 24 0.2 4.8 0 0 0 0 $0

 Report review

 Notification of construction c2 1 2 0 0 0 0 $0

 Notification of anticipated startup d0.5 1 0.1 0 0 0 0 $0

 Notification of actual startup d0.5 1 0.5 0 0 0 0 $0

 Notification of initial test d0.5 1 0.5 0 0 0 0 $0

 Review test results 8 1 8 0 0 0 0 $0

Existing Plants

 Emission reports 4.2 2 8.4 18 151.2 7.56 15.12 $7,835.86

Subtotals Labor Burden and cost 151.2 7.56 15.12 $7,83586

TOTAL ANNUAL BURDEN AND COST 174 $7,836

Assumptions:

 a

 We have assumed that there are approximately 18 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next

 three years. 

b

 This cost is based on the following hourly labor rates times a 1.6 benefits multiplication factor to account for government overhead expenses: $62.27 for 

Managerial (GS-13, Step 5, $38.92 x 1.6), $46.21 for Technical (GS-12, Step 1, $28.88 x 1.6) and $25.01 Clerical (GS-6, Step 3, $15.63 1.6). These rates are from 

the Office of Personnel Management (OPM) A2011 General Schedule@ which excludes locality rates of pay.

c

 We have assumed that all existing new sources will take 2 hours to complete report.

d

 We have assumed that all existing sources will each take 0.5 hours to complete report.

e We have assumed that all existing plants will be required to complete emission reports.