1
SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
NSPS
SUBPART
J:
PETROLEUM
REFINERIES
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
J)

1(
b)
Short
Characterization/
Abstract
The
New
Source
Performance
Standards
(
NSPS)
for
Petroleum
Refineries
for
the
standards
published
at
40
CFR
Part
60,
Subpart
J
were
proposed
on
June
11,
1973,
and
promulgated
on
March
8,
1974.
These
standards
apply
to
the
following
affected
facilities
in
petroleum
refineries:
fluid
catalytic
cracking
unit
catalyst
regenerators,
fuel
gas
combustion
devices,
and
Claus
sulfur
recovery
plants
of
more
than
20
long
tons
per
day
commencing
construction,
modification
or
reconstruction
after
the
date
of
proposal.
The
pollutants
regulated
under
this
Subpart
are
particulate
matter,
carbon
monoxide,
and
sulfur
oxides.
This
information
is
being
collected
to
assure
compliance
with
40
CFR
Part
60,
Subpart
J.

In
general,
all
NSPS
require
initial
notifications,
performance
tests,
and
periodic
reports.
Owners
or
operators
are
also
required
to
maintain
records
of
the
occurrence
and
duration
of
any
start­
up,
shutdown,
or
malfunction
in
the
operation
of
an
affected
facility,
or
any
period
during
which
the
monitoring
system
is
inoperative.
These
notifications,
reports,
and
records
are
essential
in
determining
compliance,
and
are
required
of
all
sources
subject
to
NSPS.

Any
owner
or
operator
subject
to
the
provisions
of
this
part
shall
maintain
a
file
of
these
measurements,
and
retain
the
file
for
at
least
two
years
following
the
date
of
such
measurements,
maintenance
reports,
and
records.
All
reports
are
sent
to
the
delegated
State
or
local
authority.
In
the
event
that
there
is
no
such
delegated
authority,
the
reports
are
sent
directly
to
the
EPA
Regional
Office.

Approximately
130
affected
facilities
are
currently
subject
to
the
standard.
It
is
estimated
that
on
average,
no
additional
affected
units
per
year
will
become
subject
to
the
standard
in
the
next
three
years.
This
information
is
being
collected
to
assure
compliance
with
40
CFR
Part
60,
Subpart
J.
The
average
annual
respondent
cost
for
this
ICR
will
be
$
960,646.01.

There
are
no
terms
of
clearance
for
this
ICR.
This
submission
properly
accounts
for
the
amortization
of
capital
costs
beyond
the
three
year
period
for
which
this
ICR
is
approved.
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
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
four
years.
In
the
Administrator's
judgment,
particulate
matter,
carbon
monoxide
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.

2(
b)
Practical
Utility/
Users
of
the
Data
The
control
of
emissions
of
particulate
matter,
carbon
monoxide,
and
sulfur
oxides
from
petroleum
refineries
requires
not
only
the
installation
of
properly
designed
equipment,
but
also
the
operation
and
maintenance
of
that
equipment.
Emissions
of
particulate
matter,
carbon
monoxide,
and
sulfur
oxides
from
petroleum
refineries
are
the
result
of
operation
of
fluid
catalytic
cracking
unit
catalyst
regenerators,
fuel
gas
combustion
devices
and
Claus
sulfur
recovery
plants.
For
sulfur
oxides
emissions
the
standards
rely
on
the
capture
of
sulfur
oxides
emissions
vented
to
a
control
device
or
by
allowing
a
maximum
sulfur
content
in
the
feed
stream.
The
owners
or
operators
of
affected
facilities
are
required
to
install
a
continuous
emission
monitor
and
record
the
emission
levels
of
opacity,
carbon
monoxide,
and
sulfur
dioxide
or
hydrogen
sulfide.
Owners
or
operators
are
required
to
report
all
periods
of
emissions
in
excess
of
the
standard.

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
(
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.
3
Except
for
excess
emission
data
for
SO
2,
EPA
reduced
the
reporting
frequency
for
this
information
from
quarterly
to
semiannually
in
a
December
1990
Federal
Register
Notice.
The
reduction
in
reporting
frequency
was
in
response
to
OMB's
previous
questions
regarding
the
need
for
quarterly
versus
semiannual
reporting.
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
is
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,
and
is
of
sufficient
quality
to
be
used
as
evidence
in
court.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
The
recordkeeping
and
reporting
requested
is
required
under
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.
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
the
Federal
Register
(
67
FR
4421),
on
January
30,
2002.
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.

3(
c)
Consultations
Because
petroleum
refineries
are
one
of
the
national
priority
industry
sectors
EPA
data
bases
(
such
as
AFS)
have
accurate
and
up
to
date
information
on
this
industry
so
no
consultation
beyond
the
request
for
comments
was
undertaken.
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.

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
4
collected
less
frequently,
the
likelihood
of
detecting
poor
operation
and
maintenance
of
control
equipment
and
noncompliance
would
decrease.

3(
e)
General
Guidelines
None
of
these
reporting
or
recordkeeping
requirements
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
contain
sensitive
questions.

4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
SIC
Codes
The
respondents
of
the
recordkeeping
and
reporting
requirements
are
petroleum
refineries
which
commenced
construction,
modification,
or
reconstruction
after
June
11,
1973,
for
fluid
catalytic
cracking
unit
catalyst
regenerators
or
fuel
gas
combustion
devices,
or
after
October
4,
1976,
for
any
Claus
sulfur
recovery
plants.
The
SIC
code
for
the
respondents
affected
by
the
standards
is
SIC
(
U.
S.
Standard
Industrial
Classification)
2911
which
corresponds
to
the
NAICS
(
The
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
New
Source
Performance
Standards
for
Petroleum
Refineries
(
40
CFR
Part
60,
Subpart
J).
5
A
source
must
make
the
following
reports:

Reports
for
40
CFR
Part
60,
Subpart
J
Construction/
reconstruction
60.7(
a)(
1)

Initial
notifications
60.7
Actual
Start­
up
60.7(
a)(
3)

Opacity
or
Visible
Emissions
60.7
(
a)(
6),
(
a)(
7)

Monitor
Downtime
60.107(
c)(
2)­(
4)

Excess
emissions
SO
2
60.7(
c),
60.107
(
c)(
1)
­
(
2)

Initial
performance
test
results
60.8
(
a)

Notification
of
initial
performance
test
60.8(
d)

Rescheduled
initial
performance
test
60.108
Demonstration
of
continuous
monitoring
system
(
CMS)
60.7(
a)(
5)

Notification
of
Compliance
status
60.11(
a),(
b),(
c)

Physical
or
Operational
Change
60.7(
a)(
4)

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

Semiannual
Reports
60.107(
e)

A
Signed
Statement
60.107(
d),(
f)

A
source
must
keep
the
following
records:

Recordkeeping
for
40
CFR
Part
60,
Subpart
J
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
60.106
Excess
emissions
and
monitor
downtime
data
60.107(
b)(
1)­(
4)

(
ii)
Respondent
Activities
6
Respondent
Activities
Read
instructions.

Gather
relevant
information.

Install,
calibrate,
maintain,
and
operate
CMS
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.

Continuous
Monitoring
System
(
CMS)
information
collection
is
automated
and
may
be
submitted
electronically.
In
any
event,
hard
copy
reports
from
the
CMS
information
may
easily
be
generated
from
a
computer.
It
is
estimated
that
70%
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
EPA
conducts
the
following
activities
in
connection
with
the
acquisition,
analysis,
storage,
and
distribution
of
the
required
information.
7
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,
and
excess
emissions
reports,
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
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
quarterly
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.
EPA
uses
AFS
for
tracking
air
pollution
compliance
and
enforcement
by
State
and
local
regulatory
agencies,
EPA
Regional
Offices
and
EPA
Headquarters.
EPA
and
its
delegated
Authorities
can
edit,
store,
retrieve
and
analyze
the
data.

The
records
required
by
this
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
(
e.
g.,
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
J
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
Agency
considers
these
requirements
the
minimum
needed
to
ensure
compliance
8
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
J.

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.

6(
a)
Estimating
Respondent
Burden
The
average
annual
burden
to
industry
over
the
next
three
years
from
these
recordkeeping
and
reporting
requirements
is
estimated
to
be
11,375
(
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
$
55.34
($
26.35
+
110%
overhead)
per
hour.
This
rate
is
from
the
United
States
Department
of
Commerce,
Bureau
of
Labor
Statistics,
March
2000,
"
Table
10.
Private
industry,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
wage
rate
has
been
increased
by
110%
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
Emissions
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
9
photocopying
and
postage.
Since
there
are
no
new
sources
on
average
anticipated
over
the
next
3
years
there
are
no
capital
costs
associated
with
this
information
collection.

(
iii)
Capital/
Start­
up
vs.
Operating
and
Maintenance
(
O&
M)
Costs
Since
there
are
no
new
sources
on
average
anticipated
over
the
next
3
years
there
are
no
capital
costs
associated
with
this
information
collection.
Capital/
startup
costs
are
shown
in
block
14(
a),
Total
annualized
capital/
startup
costs,
on
the
OMB
83­
I
form.
It
should
be
noted
that
the
numbers
in
block
14
of
the
OMB
83­
I
form
are
rounded
to
show
the
cost
in
thousands
of
dollars.

The
total
operation
and
maintenance
(
O&
M)
costs
for
this
ICR
are
$
91,000.
This
is
based
on
130
existing
sources
multiplied
by
$
700
dollars
(
increasing
from
the
last
ICR
to
reflect
the
current
Consumer
Price
Index)
for
upkeep
of
the
monitoring
device.
These
costs
are
shown
in
block
14(
b),
Total
annual
costs
(
O&
M),
on
the
OMB
83­
I
form.

The
total
respondent
non­
labor
costs
in
block
14
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
$
91,000
.
This
cost
is
shown
on
the
OMB
83­
I
form
in
block
14
(
c),
Total
annualized
cost
requested.

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
the
ICR
is
estimated
to
be
$
14,630
(
see
Table
1:
Average
Annual
EPA
Resource
Requirements
Resulting
From
NSPS
Subpart
J).
This
cost
is
based
on
the
average
hourly
labor
rate
at
a
GS­
12,
Step
1
($
23.94),
times
a
1.6
benefits
multiplication
factor
to
account
for
government
overhead
expenses
for
a
total
of
$
38.30.
These
rates
are
from
OPM's
"
2002
General
Schedule"
which
excludes
locality
rates
of
pay.
Details
upon
which
this
estimate
is
based
appear
in
Table
1.

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
Sources
(
C)
No.
of
Existing
Sources
(
D)
No.
of
Reports
for
Existing
Sources
(
E)
Total
Annual
Responses
(
AxB)+(
CxD)
Respondent
Universe
10
40
CFR
Part
60,
Subpart
J
0
4
130
2
260
The
number
of
total
respondents
is
130.
This
number
is
the
sum
of
Column
A
and
Column
C
of
the
Respondent
Universe
table
above.
This
represents
the
number
of
existing
sources
plus
the
number
of
anticipated
new
sources
over
the
three­
year
period
of
this
ICR.
It
is
shown
in
block
13(
a),
Number
of
respondents,
on
the
OMB
83­
I
form.

The
number
of
Total
Annual
Responses
is
260.
This
is
the
number
in
Column
E
of
the
Respondent
Universe
table
above.
It
is
shown
in
block
13
(
b),
Total
annual
responses,
on
the
OMB
83­
I
form.
The
total
annual
labor
costs
are
$
767,178.37.
This
number
is
not
shown
on
the
OMB
83­
I
form
in
block
13(
c),
Total
hours
requested.
Only
the
burden
hours
are
reflected
in
block
13(
c).
Details
upon
which
this
estimate
is
based
appear
in
Table
2:
Industry
Burden
From
Recordkeeping
and
Reporting
­
NSPS
Subpart
J.

The
total
annual
capital
and
O&
M
costs
to
the
regulated
entity
are
$
91,000.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
14
(
c),
Total
annualized
cost
requested.
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
The
decrease
in
burden
from
the
most
recently
approved
ICR
is
due
to
an
adjustment
in
labor
rates
and
a
correction
in
calculation
errors
from
the
prior
ICR..
The
previous
ICR
counted
1.5
affected
units
per
refinery
for
the
respondents,
and
this
ICR
counts
each
refinery
as
a
respondent.
Also
the
previous
ICR
did
not
properly
account
for
quarterly
reporting.

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
11
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.

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
Susan
Auby,
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.
12
TABLE
1:
AVERAGE
ANNUAL
EPA
RESOURCE
REQUIREMENTS
RESULTING
FROM
NSPS
SUBPART
J
(
A)
(
B)
(
C)
a
(
D)
(
E)
c
EPA
hours/
Occurrences/
EPA
hours/
Plants/
EPA
hours/

Activity
Occurrence
plant/
year
plant
year
yearb
year
New
Plants:
d
_________________________________
Not
Applicable
__________________________________________________

Existing
Plants:

Quarterly
Emission
Reports
1
4
4
84
336
Semiannual
Emission
Reports
0.5
2
1
46
46
TOTAL
ANNUAL
HOURS
382
Salary:
e
(
382
hours/
year
*
$
38.30/
hour)
=
$
14,630/
year
TOTAL
ANNUAL
COST
=
$
14,630
))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))

a
A
*
B
=
C
b
Assume
that
65%
of
the
130
plants
will
have
at
least
one
quarter
with
excess
emissions,
and
35%
will
report
semiannually.

c
C
*
D
=
E
d
Assume
that
on
average,
no
new
sources
will
be
subject
to
Subpart
J
e
Estimate
an
hourly
wage
of
$
23.94
plus
60%
overhead
expense
which
equals
$
38.30.
13
TABLE
2:
INDUSTRY
BURDEN
FROM
RECORDKEEPING
AND
REPORTING
­
NSPS
SUBPART
J
a
Occurrences/
Hours/
Total
Labor
Cost
Hours
per
respondent/
respondent/
Responses
Hours
per
Occurrence
year
year
per
year
per
year
yearc
(
A)
(
B)
(
C
=
A
*
B)
(
D)
(
E
=
C
*
D)
(
F)

1.
APPLICATIONS
____________________________________
Not
Applicable
_____________________________________________

2.
SURVEY
AND
STUDIES
____________________________________
Not
Applicable
_____________________________________________

3.
REPORTING
REQUIREMENTS
A.
Read
Instructionsb
1
1
1
7
7
$
387.38
B.
Required
Activities
Performance
testb
Relative
Accuracy
Testb
146
1
146
7
51d
$
2,822.34
CEMS
Audits
(
RAA
or
CGA)
b
160
2
320
7
112d
$
6,198.03
C.
Create
Information
Included
in
3B
D.
Gather
Existing
Information
Included
in
3E
E.
Write
Report
Notification
Requirementsa
______________________________________
Not
Applicable
___________________________________________

Report
of
performance
testb
2
1
2
7
14
$
774.76
Quarterly
Emission
Reports
4
4
16
340f
5,440
$
301,049.60
Semiannual
Emission
Reports
2
2
4
90f
360
$
19,922.40
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
0.25
350e
87.5
130
11,375
$
629,492.50
Records
of
operating
parameters
F.
Train
Personnel
____________________________________
Not
Applicable
_____________________________________________

G.
Audits
____________________________________
Not
Applicable
_____________________________________________

))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))

5.
TOTAL
ANNUAL
BURDEN
17,359
$
960,646.01
))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))))

a
Assume
that
on
average,
no
new
sources
will
be
subject
to
Subpart
J.
Therefore,
estimate
is
for
existing
sources
only.

b
Assume
the
5%
of
the
existing
sources
are
requested
by
the
regulatory
agency
to
conduct
a
performance
test.

c
Assume
an
hourly
wage
of
$
26.35
plus
110
percent
overhead
costs
which
equals
$
55.34.
This
amount
was
multiplied
by
the
hours
per
year
in
Column
E.

d
Person­
hours
and
annual
cost
are
estimated
to
be
5%
of
the
time
that
a
CEMS
is
in
operation.
(
E=.
05CxD)

e
Assume
operation
350
days
per
year
as
specified
in
the
NSPS
review
document
f
Assume
that
65%
(
85/
130)
of
respondents
will
have
quarterly
reports
and
35%
(
45/
130)
will
report
semiannually.
