SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
NESHAP
for
Petroleum
Refineries
(
40
CFR
part
63,
subpart
CC)
(
Renewal)

1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
NESHAP
for
Petroleum
Refineries
(
40
CFR
part
63,
subpart
CC)
(
Renewal)

1(
b)
Short
Characterization/
Abstract
The
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
From
Petroleum
Refineries,
published
at
40
CFR
part
63,
subpart
CC,
were
proposed
on
July
15,
1994,
and
promulgated
on
August
18,
1995.
These
regulations
apply
to
the
following
existing
and
new
petroleum
refining
process
units
and
emission
points
located
at
refineries
that
are
major
sources
of
HAPs:
miscellaneous
process
vents,
storage
vessels,
wastewater
streams
and
treatment
operations,
equipment
leaks,
gasoline
loading
racks,
and
marine
vessel
loading
operations.
These
regulations
also
apply
to
storage
vessels
and
equipment
leaks
associated
with
bulk
gasoline
terminals
or
pipeline
breakout
stations
that
are
related
to
an
affected
petroleum
refinery.
New
facilities
include
those
that
commenced
construction
or
reconstruction
after
the
date
of
proposal.
This
information
is
being
collected
to
assure
compliance
with
40
CFR
part
63,
subpart
CC.

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

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
five
years
following
the
date
of
such
measurements,
maintenance
reports,
and
records.
All
reports
are
sent
to
the
delegated
state
or
local
authority.
In
the
event
that
there
is
no
such
delegated
authority,
the
reports
are
sent
directly
to
the
United
States
Environmental
Protection
Agency
(
EPA)
regional
office.
Once
received
by
the
authority,
reports
are
reviewed
and
the
data
is
entered,
analyzed,
and
maintained
in
the
Air
Facility
System
(
AFS).
Information
from
these
reports
can
be
used
by
any
regions,
states,
agencies
and
offices
with
access
to
AFS
and
may
be
used
in
determining
where
inspections
and
enforcement
actions
may
be
necessary.

Approximately
134
sources
are
currently
subject
to
the
regulation,
and
it
is
estimated
that
no
additional
sources
per
year
will
become
subject
to
the
regulation
in
the
next
three
years.
Although
no
additional
sources
are
expected
to
become
subject
to
the
regulation,
some
sources
will
construct
new
affected
facilities
or
will
reconstruct
currently
affected
facilities
in
order
to
2
increase
their
refining
capacities.
It
is
assumed
that,
on
average,
a
refinery
will
reconstruct
ten
percent
of
the
existing
storage
vessels,
process
units
subject
to
equipment
leak
provisions,
and
process
vents.
The
annual
cost
of
this
ICR
will
be
$
0
dollars
for
nonlabor
and
$
26,163,230
for
labor
(
based
on
a
labor
burden
of
410,054
hours)
for
a
total
of
$
26,163,230
dollars.

These
estimates
are
based
on
the
Oil
and
Gas
Journal's
Pennwell
Surveys,
industry
contacts,
and
information
from
the
previous
ICR.

The
OMB
approved
the
currently
active
ICR
without
any
"
Terms
of
Clearance."

2.
Need
for
and
Use
of
the
Collection
2(
a)
Need/
Authority
for
the
Collection
The
EPA
is
charged
under
Section
112
of
the
Clean
Air
Act,
as
amended,
to
establish
standards
of
performance
for
each
category
or
subcategory
of
major
sources
and
area
sources
of
hazardous
air
pollutants.
These
standards
are
applicable
to
new
or
existing
sources
of
hazardous
air
pollutants
and
shall
require
the
maximum
degree
of
emission
reduction.
In
addition,
Section
114(
a)
states
that
the
Administrator
may
require
any
owner
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
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,
HAP
emissions
from
petroleum
refineries
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
the
NESHAP
were
promulgated
for
this
source
category
at
40
CFR
part
63,
subpart
CC.

2(
b)
Practical
Utility/
Users
of
the
Data
The
control
of
emissions
of
HAP
from
petroleum
refineries
requires
not
only
the
3
installation
of
properly
designed
equipment,
but
also
the
operation
and
maintenance
of
that
equipment.
Emissions
of
HAP
from
petroleum
refineries
are
the
result
of
operation
of
the
affected
facilities.
The
subject
standards
are
achieved
by
the
capture
of
HAP
emissions
using
control
devices
and
the
reduction
of
emissions
through
leak
detection
and
repair
procedures.
Depending
on
the
emission
point
being
controlled,
affected
sources
may
use
flares,
carbon
adsorbers,
combustion
devices
(
including
incinerators,
boilers
and
process
heaters),
or
other
control
devices
that
meet
minimum
control
requirements.
The
notifications
required
in
the
applicable
regulations
are
used
to
inform
the
Agency
or
delegated
authority
when
a
source
becomes
subject
to
the
requirements
of
the
regulations.
The
reviewing
authority
may
then
inspect
the
source
to
check
if
the
pollution
control
devices
are
properly
installed
and
operated,
leaks
are
being
detected
and
repaired,
and
the
regulations
are
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
standards,
and
serve
as
a
record
of
the
operating
conditions
under
which
compliance
was
achieved.
In
general,
control
devices
other
than
flares
must
achieve
HAP
reductions
of
at
least
95
percent
by
weight.
Flares
must
be
operated
with
no
visible
emissions
and
a
flame
must
be
present
at
all
times.
The
semiannual
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.
The
information
generated
by
the
monitoring,
recordkeeping
and
reporting
requirements
described
in
this
ICR
is
used
by
the
Agency
to
ensure
that
sources
affected
by
the
NESHAP
continue
to
operate
the
control
equipment
in
compliance
with
the
regulation.
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
and
is
of
sufficient
quality
to
be
used
as
evidence
in
court.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
The
requested
recordkeeping
and
reporting
are
required
under
40
CFR
part
63,
subpart
CC.

3(
a)
Nonduplication
If
the
subject
standards
have
not
been
delegated,
the
information
is
sent
directly
to
the
appropriate
EPA
regional
office.
Otherwise,
the
information
is
sent
directly
to
the
delegated
state
or
local
agency.
If
a
state
or
local
agency
has
adopted
its
own
similar
standards
to
implement
the
Federal
standards,
a
copy
of
the
report
submitted
to
the
state
or
local
agency
can
be
sent
to
the
Administrator
in
lieu
of
the
report
required
by
the
Federal
standards.
Therefore,
no
duplication
exists.

Some
of
the
facilities
subject
to
this
NESHAP
will
also
be
subject
to
requirements
under
the
New
Source
Performance
Standards
(
NSPS)
subparts
J,
K,
Ka,
Kb,
VV,
and
QQQ,
NESHAP
(
part
61)
subpart
FF,
and
NESHAP
(
part
63)
subparts
G,
H,
J,
R,
and
Y.
The
burden
requested
for
this
NESHAP
does
not
duplicate
any
of
the
burden
accounted
for
under
those
subparts.
4
Efforts
were
made
before
and
after
promulgation
to
streamline
overlapping
recordkeeping
and
reporting
requirements
of
other
rules
affecting
the
petroleum
refinery
industry.
The
applicability
section
of
this
NESHAP
delineates
requirements
where
there
are
overlapping
rules.

This
NESHAP
does
not
require
additional
recordkeeping
or
reporting
for
marine
vessel
tank
loading
and
unloading
operations,
bulk
gasoline
loading
racks,
and
wastewater
sources,
provided
that
they
are
not
included
in
emissions
averaging.
These
sources
would
only
be
affected
by
those
records
and
reports
required
already
by
other
rules.
Therefore,
the
recordkeeping
and
reporting
cost
for
these
sources
was
not
included
in
the
burden
estimate
for
this
rule.

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
(
69
FR
29718)
on
May
25,
2004.
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.

3(
c)
Consultations
In
addition
to
holding
a
public
comment
period
following
the
First
Federal
Register
Notice
(
FFRN),
the
EPA
consulted
with
industry
representatives
(
i.
e.,
respondents)
(
Tom
Wigglesworth,
National
Petroleum
Refiners
Association,
202­
457­
0480)
and
industry
trade
association
journals
to
obtain
information
about
the
regulated
universe.
The
Oil
and
Gas
Journal's
PennWell
Surveys
were
the
primary
sources
of
information
regarding
the
number
of
existing
affected
sources.
Consultations
with
industry
representatives
were
used
to
verify
such
information
and
provide
other
key
data
(
e.
g.,
industry
growth
rate,
level
of
electronic
reporting).
The
EPA
databases
OTIS
(
Online
Tracking
Information
System)
and
TRI
(
Toxic
Release
Inventory)
were
also
consulted.

EPA
solicited
input
from
industry
representatives
to
determine
whether
it
would
be
possible
to
reduce
the
recordkeeping
and
reporting
burden
or
improve
the
language
in
the
standards
to
facilitate
industry
compliance.
EPA
did
not
receive
any
suggestions
on
how
to
revise
the
rule.

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.
5
3(
e)
General
Guidelines
None
of
these
reporting
or
recordkeeping
requirements
violate
any
of
the
regulations
established
by
OMB
at
5
CFR
1320.5.

These
standards
require
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
the
Part
70
permit
program
and
the
five
year
statute
of
limitations
on
which
the
permit
program
is
based.
Also,
the
retention
of
records
for
five
years
would
allow
EPA
to
establish
the
compliance
history
of
a
source
and
any
pattern
of
compliance
for
purposes
of
determining
the
appropriate
level
of
enforcement
action.
Historically,
EPA
has
found
that
the
most
flagrant
violators
frequently
have
violations
extending
beyond
the
five
years.
EPA
would
be
prevented
from
pursuing
the
worst
violators
due
to
the
destruction
or
nonexistence
of
records
if
records
were
retained
for
less
than
five
years.

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
(
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
None
of
the
reporting
or
recordkeeping
requirements
contain
sensitive
questions.

4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
SIC
Codes
The
respondents
to
the
recordkeeping
and
reporting
requirements
are
petroleum
refineries
that
are
major
sources
of
HAP
emissions.
The
SIC
code
for
the
respondents
affected
by
the
standards
is
SIC
(
United
States
Standard
Industrial
Classification)
2911,
which
corresponds
to
NAICS
(
North
American
Industry
Classification
System)
324110
for
petroleum
refineries.

4(
b)
Information
Requested
(
i)
Data
Items
6
All
data
in
this
ICR
that
are
recorded
and/
or
reported
are
required
by
40
CFR
part
63,
subpart
CC
­
National
Emission
Standards
for
Hazardous
Air
Pollutants
From
Petroleum
Refineries.

A
source
must
make
the
following
reports:

Notification
Reports
Notification
of
Compliance,
Status
Report,
Periodic
Report
for
Emissions
Averaging
(
optional)
63.653(
a)
&
(
c)

Notification
of
intent
to
construct/
reconstruct.
63.9(
b)(
4),
63.654(
d)(
2)

Notification
of
date
of
construction/
reconstruction.
63.9(
b)(
4),
63.654(
d)(
2)

Notification
of
date
of
actual
startup.
63.9(
b)(
4),
63.654(
d)(
2)

Application
for
approval
of
construction/
reconstruction.
63.5(
d),
63.9(
b)(
5),
63.566(
b),
63.640(
k)(
2)(
i),
63.654(
c),
63.654(
h)(
6)

Notification
of
intent
to
construct/
reconstruct
a
control
device.
63.5(
b)(
6),
63.5(
d)(
1)

Notification
of
Compliance
Status.
63.182(
c),
63.428(
c)(
2),
63.640(
k)(
2)(
ii),
63.654(
b),
63.654(
d),
63.654(
f),
63.654(
h)(
6)

Notification
of
performance
test
and
site­
specific
test
plan.
63.567(
d),
(
f),
63.642(
d)(
2),
63.654(
c),

Results
of
performance
test.
63.567(
d),
63.654(
c),
63.654(
d)
7
Notification
Reports
Request
for
extension
of
compliance.
63.9(
c)

Notification
of
special
compliance
requirements.
63.9(
d)

Engineering
report
of
vapor
collection
system
for
marine
tank
vessel
loading
operations.
63.567(
f),
63.654(
c)

Notifications
for
wastewater
streams.
61.357,
63.654(
a)

Notifications
of
inspections
of
storage
vessels.
63.654(
h)(
2)

Notification
of
determination
of
applicability
to
flexible
process
units.
63.654(
h)(
6)(
i)

Notification
of
determination
of
applicability
to
variable
storage
vessels.
63.654(
h)(
6)(
ii)

Notification
of
determination
of
applicability
to
variable
distillation
units.
63.654(
h)(
6)(
iii)

Reports
Submission
of
Implementation
Plan
for
approval
(
optional)
63.652(
b),
63.653(
c)
&
(
d)

Periodic
Report
for
Emissions
Averaging
(
optional)
63.652(
l)

Reports
for
wastewater
streams.
61.357,
63.654(
a)

Reports
for
gasoline
loading
racks.
63.428(
b),
(
c),
(
g)(
1),
and
(
h)(
1)
through
(
h)(
3),
63.654(
b)

Annual
reports
of
excess
emissions
and
continuous
monitoring
system
performance,
or
summary
report,
for
marine
tank
vessel
loading
operations.
63.567(
e),
63.654(
c)

Reports
for
equipment
leaks.
60.487
or
63.182,
63.654(
d)
8
Reports
Semiannual
("
Periodic")
and
immediate
reports,
including
startup,
shutdown,
and
malfunction
reports.
63.10(
d)(
5),
63.654(
g),
63.654(
h)(
1)

A
source
must
keep
the
following
records:

Recordkeeping
Records
for
Implementation
Plan
(
optional)
63.653(
a),
(
b),
&
(
d)

Records
for
wastewater
streams.
61.356,
63.654(
a)

Records
for
gasoline
loading
racks.
63.428(
c),
63.654(
b)

Records
for
vapor
collection
system
for
marine
tank
vessel
loading
operations.
63.567(
g),
63.654(
c)

Records
of
vapor
tightness
for
marine
tank
vessel
loading
operations.
63.567(
h),
63.654(
c)

Records
of
current
vapor
tightness
test
results
for
marine
tank
vessel
loading
operations.
63.567(
i),
63.654(
c)

Records
for
equipment
leaks.
60.486
or
63.181,
63.654(
d)

Records
for
storage
vessels.
63.123,
63.654(
i)(
1)

Records
of
performance
test
results
and
test
reports.
63.654(
i)(
2)

Records
for
monitoring
of
miscellaneous
process
vents.
63.654(
i)(
3)

Records
of
miscellaneous
notifications
and
reports.
63.654(
i)(
4)

Records
of
startup,
shutdown,
and
malfunction
of
processes.
63.10(
b)(
2)(
i)

Records
of
malfunction
of
control
equipment.
63.10(
b)(
2)(
ii)

Records
of
corrective
actions
taken
during
periods
of
startup,
shutdown,
and
malfunction.
63.10(
b)(
2)(
iv)
9
Recordkeeping
1
Consultation
with
Norbert
Dee
and
Tom
Bigglesworth,
National
Petroleum
Refiners
Association.
Records
to
demonstrate
conformance
with
startup,
shutdown,
and
malfunction
plan.
63.10(
b)(
2)(
v)

Records
of
calibration
checks,
adjustments
and
maintenance
on
CMS.
63.10(
b)(
x),
(
xi)

Electronic
Reporting
The
majority
of
the
recordkeeping
requirements
associated
with
this
rule
are
related
to
visual
inspections
of
affected
facilities.
Personnel
at
the
affected
source
must
perform
these
inspections
and
note
the
nature
of
the
corrective
actions
taken.
Because
of
the
human
labor
involved
with
these
requirements,
there
are
few
record
keeping
requirements
that
could
be
easily
automated.
As
a
result,
automated
record
keeping
appears
to
be
rare
among
respondents.
Some
regulatory
agencies
are
setting
up
electronic
reporting
systems
to
allow
sources
to
report
electronically
which
is
reducing
the
reporting
burden.
However,
electronic
reporting
systems
are
still
not
widely
used
by
the
regulatory
agencies.
It
is
believed
that
electronic
reporting
is
not
common
among
respondents1.

(
ii)
Respondent
Activities
Respondent
Activities
Read
instructions.

Install,
calibrate,
maintain,
and
operate
continuous
temperature
monitors
or
other
monitoring
devices
for
HAP
control
devices.

Perform
initial
performance
test
and
repeat
performance
tests
if
necessary.

Write
the
notifications
and
reports
listed
above.

Enter
information
required
to
be
recorded
above.

Submit
the
required
reports
developing,
acquiring,
installing,
and
utilizing
technology
and
systems
for
the
purpose
of
collecting,
validating,
and
verifying
information.

Develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purpose
of
processing
and
maintaining
information.
10
Respondent
Activities
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.

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
observe
repeat
performance
tests
if
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
Air
Facility
System
(
AFS).

5(
b)
Collection
Methodology
and
Management
Following
notification
of
startup,
the
reviewing
authority
may
inspect
the
source
to
check
if
the
pollution
control
devices
are
properly
installed
and
operated,
leaks
are
being
detected
and
repaired,
and
the
regulations
are
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
standards,
and
serve
as
a
record
of
the
operating
conditions
under
which
compliance
was
achieved.
In
general,
control
devices
other
than
flares
must
achieve
HAP
reductions
of
at
least
95
percent
by
weight.
Flares
must
be
operated
with
no
visible
emissions
and
a
flame
must
be
present
at
all
times.
Data
and
records
maintained
by
the
respondents
are
tabulated
and
published
for
use
in
compliance
and
11
2
Consultation
with
Norbert
Dee
and
Tom
Bigglesworth,
National
Petroleum
Refiners
Association.
enforcement
programs.
The
semiannual
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.

Information
contained
in
the
reports
is
entered
into
the
AFS,
which
is
operated
and
maintained
by
EPA's
Office
of
Compliance.
AFS
is
EPA's
database
for
the
collection,
maintenance,
and
retrieval
of
compliance
data
for
approximately
125,000
industrial
and
government­
owned
facilities.
EPA
uses
the
AFS
for
tracking
air
pollution
compliance
and
enforcement
by
local
and
state
regulatory
agencies,
EPA
regional
offices
and
EPA
headquarters.
EPA
and
its
delegated
Authorities
can
edit,
store,
retrieve
and
analyze
the
data.

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

5(
c)
Small
Entity
Flexibility
A
majority
of
the
affected
facilities
are
large
entities
(
e.
g.,
large
businesses)
2.
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
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
in
Table
1:
Annual
Respondent
Burden
and
Cost,
NESHAP
for
Petroleum
Refineries
(
40
CFR
part
63,
subpart
CC).

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.
Where
appropriate,
specific
tasks
and
major
assumptions
have
been
identified.
Responses
to
this
information
collection
are
mandatory.
12
In
the
original
burden
estimate,
it
was
assumed
that
50
percent
of
refineries
complying
with
the
petroleum
refineries
NESHAP
would
make
use
of
the
emissions
averaging
provisions.
Emissions
averaging
allows
regulated
facilities
to
control
emission
points
to
levels
less
than
required
by
the
rule
if
other
emission
points
are
controlled
to
levels
greater
than
required
by
the
rule.
Additional
recordkeeping
and
reporting
is
required
of
refineries
using
emissions
averaging
in
order
to
ensure
that
the
net
decrease
in
emissions
achieved
is
greater
than
the
decrease
that
would
have
been
achieved
without
emissions
averaging.

Currently,
it
is
expected
none
of
the
refineries
subject
to
the
NESHAP
will
use
emissions
averaging.
The
date
has
passed
by
which
facilities
are
required
to
submit
an
implementation
plan
(
required
when
applying
for
emissions
averaging)
and
no
implementation
plans
have
been
received.
Consequently,
no
hours
are
included
in
the
estimated
burden
for
recordkeeping
and
reporting
activities
associated
with
emissions
averaging.

Also,
as
discussed
in
Section
3(
a),
no
hours
are
included
in
the
estimated
burden
for
recordkeeping
and
reporting
activities
associated
with
marine
vessel
tank
loading
and
unloading
operations,
bulk
gasoline
loading
racks,
and
wastewater
sources.
The
petroleum
refineries
NESHAP
does
not
have
any
additional
recordkeeping
or
reporting
requirements
for
these
sources,
provided
that
they
are
not
included
in
emissions
averaging.

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
410,054
hours.
These
hours
are
based
on
Agency
studies
and
background
documents
from
the
development
of
the
regulation,
Agency
knowledge
and
experience
with
the
NESHAP
program,
the
previously
approved
ICR,
and
any
comments
received.

6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
This
ICR
uses
the
following
labor
rates:

Managerial
$
95.32
($
45.39
+
110%)
Technical
$
64.60
($
30.76
+
110%)
Clerical
$
40.09
($
19.09
+
110%)
13
These
rates
are
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
December,
2003,
"
Table
10.
Private
industry,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
rates
have
been
increased
by
110%
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.

(
ii)
Estimating
Capital/
Startup
and
Operation
and
Maintenance
Costs
The
only
costs
to
the
regulated
industry
resulting
from
information
collection
activities
required
by
the
subject
standard
are
labor
costs.
There
are
no
capital/
startup
or
operation
and
maintenance
costs.

(
iii)
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
The
petroleum
refineries
NESHAP
incorporates
requirements
for
parametric
monitoring
of
control
devices
that
are
included
in
other
rules
to
which
petroleum
refineries
are
already
subject.
No
additional
new
monitoring
equipment
is
required
in
order
to
comply
with
the
recordkeeping
and
reporting
requirements
of
the
petroleum
refineries
NESHAP.
Therefore,
no
capital/
startup
or
operation
and
maintenance
costs
are
associated
with
this
rule.

The
total
capital/
startup
costs
for
this
ICR
are
$
0.
These
costs
are
shown
on
the
OMB
83­
I
form
in
block
14(
a),
Total
annualized
capital/
startup
costs.

The
total
operation
and
maintenance
(
O&
M)
costs
for
this
ICR
are
$
0.
These
costs
are
shown
on
the
OMB
83­
I
form
in
block
14(
b),
Total
annual
costs
(
O&
M).

The
total
respondent
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
$
0.
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.
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
$
165,485.
14
This
cost
is
based
on
the
average
hourly
labor
rate
as
follows:

Managerial
$
54.66
(
GS­
13,
Step
5,
$
34.16
x
1.6)
Technical
$
40.56
(
GS­
12,
Step
1,
$
25.35
x
1.6)
Clerical
$
21.95
(
GS­
6,
Step
3,
$
13.72
x
1.6)

These
rates
are
from
the
Office
of
Personnel
Management
(
OPM)
"
2004
General
Schedule"
which
excludes
locality
rates
of
pay.
Details
upon
which
this
estimate
is
based
appear
in
Table
2:
Annual
Agency
Burden
and
Cost,
NESHAP
for
Petroleum
Refineries
(
40
CFR
part
63,
subpart
CC),
below.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Based
on
our
research
for
this
ICR,
approximately
134
existing
sources
are
currently
subject
to
the
standard.
It
is
estimated
that
no
additional
sources
per
year
will
become
subject
to
the
standard
in
the
next
three
years.
Although
no
additional
sources
are
expected
to
become
subject
to
the
regulation,
some
sources
will
construct
new
affected
facilities
or
will
reconstruct
currently
affected
facilities
in
order
to
increase
their
refining
capacities.
It
is
assumed
that,
on
average,
a
refinery
will
reconstruct
ten
percent
of
the
existing
storage
vessels,
process
units
subject
to
equipment
leak
provisions,
and
process
vents.

The
number
of
respondents
is
calculated
using
the
following
table,
which
addresses
the
three
years
covered
by
this
ICR.

Number
of
Respondents
Respondents
That
Submit
Reports
Respondents
That
Do
Not
Submit
Any
Reports
Year
(
A)
Number
of
New
Respondents
(
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
Respondents1
(
E)
Number
of
Respondents
(
E=
A+
B+
C­
D)

1
13
134
0
13
134
2
13
134
0
13
134
3
13
134
0
13
134
Average
13
134
0
13
134
15
1
New
respondents
include
sources
with
constructed
and
reconstructed
affected
facilities.
In
this
standard
existing
respondents
submit
initial
notifications.

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
134.
This
number
appears
on
the
OMB
83­
I
form
in
block
13(
a),
Number
of
respondents.

The
total
number
of
annual
responses
per
year
is
calculated
using
the
following
table.
Note
that
this
table
does
not
account
for
responses
that
are
required
by
other
regulations
to
which
petroleum
refineries
are
already
subject
(
i.
e.,
requirements
that
are
not
attributable
to
the
petroleum
refineries
NESHAP):

Total
Annual
Responses
(
A)

Information
Collection
Activity
(
B)

Number
of
Respondents
(
C)

Number
of
Responses
(
D)
Number
of
Existing
Respondents
That
Keep
Records
But
Do
Not
Submit
Reports
(
E)
Total
Annual
Responses
E=(
BxC)+
D
Notification
of
construction/
reconstruction
of
process
vents
67
1
0
67
Notification
of
actual
startup
of
process
vents
67
1
0
67
Notification
of
performance
test
of
process
vents
20
1
0
20
Notification
of
compliance
status
134
1
0
134
Semiannual
reports
67
2
0
134
Annual
tank
inspection
failure
reports
67
1
0
67
Total
489
The
number
of
Total
Annual
Responses
is
489.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
13(
b),
Total
annual
responses.

The
Total
Hours
Requested
is
shown
on
the
OMB
83­
I
form
in
block
13(
c).
The
total
annual
labor
costs
are
$
26,163,236.
The
annual
labor
costs
are
not
shown
on
the
OMB
83­
I
form.
Details
regarding
these
estimates
may
be
found
in
Table
1:
Annual
Respondent
Burden
and
Cost,
NESHAP
for
Petroleum
Refineries
(
40
CFR
part
63,
subpart
CC),
below.
16
17
Table
1:
Annual
Respondent
Burden
and
Cost,
NESHAP
for
Petroleum
Refineries
(
40
CFR
Part
63,
Subpart
CC)

Activity
Technical
Hrs/
Occurrence
(
A)
Occurrences
/
Respondent
/
Yr.

(
B)
Hours/
Respondent/

Yr.

(
C)

(
C
=
A
x
B)
#
Respondents
(
D)
Technical
Hrs/
Yr.

(
E)

(
E
=
C
x
D)
Management
Hours/
Yr.

(
F)

(
F
=
0.05
x
E)
Clerical
Hours/

Yr.

(
G)

(
G
=
0.1
x
E)
Total
Labor
Costs/
Yr.
($)

(
H)
1
Assumptions
1.
Applications
Not
applicable
2.
Survey
and
Studies
Not
applicable
3.
Reporting
Requirements
A.
Read
instructions
Initial
i.
Applicability/
general
recordkeeping
and
reporting
20
1
20
13
260
13
26
19,078
Assumed
10%
of
respondents
are
adding
new
affected
facility
per
year,
and
must
therefore
read
instructions
ii.
Storage
vessels
20
1
20
13
260
13
26
19,078
iii.
Equipment
leaks
20
1
20
13
260
13
26
19,078
iv.
Process
vents
20
1
20
13
260
13
26
19,078
Periodic
v.
Applicability/
general
recordkeeping
and
reporting
4
2
8
134
1,072
53.6
107.2
78,658
vi.
Storage
vessels
1
2
2
134
268
13.4
26.8
19,665
vii.
Equipment
leaks
2
2
4
134
536
26.8
53.6
39,329
viii.
Process
vents
2
2
4
134
536
26.8
53.6
39,329
B.
Required
activities
Table
1:
Annual
Respondent
Burden
and
Cost,
NESHAP
for
Petroleum
Refineries
(
40
CFR
Part
63,
Subpart
CC),
Continued
18
Activity
Technical
Hrs/
Occurrence
(
A)
Occurrences
/
Respondent
/
Yr.

(
B)
Hours/
Respondent/

Yr.

(
C)

(
C
=
A
x
B)
#
Respondents
(
D)
Technical
Hrs/
Yr.

(
E)

(
E
=
C
x
D)
Management
Hours/
Yr.

(
F)

(
F
=
0.05
x
E)
Clerical
Hours/

Yr.

(
G)

(
G
=
0.1
x
E)
Total
Labor
Costs/
Yr.
($)

(
H)
1
Assumptions
Initial
i.
Storage
vessels
­

perform
design
analysis
and
establish
operating
parameters
for
one
closed
vent
system
80
0.9
72
134
9,648
482.4
964.8
707,922
80
hrs/
closed
vent
system,
9
vessels
with
controls,
10%

reconstructed
ii.
Equipment
leaks
2
1.1
2.2
134
294.8
14.74
29.48
21,631
2
hrs/
unit,
11
units
per
respondent,

10%
reconstructed
iii.
Process
vents
­

initial
performance
test
10
0.2
2
134
268
13.4
26.8
19,665
10
hrs/
test,
2
control
devices
for
vents,
10%
of
controls
reconstructed
iv.
Process
vents
­

repeat
performance
test
10
0.1
1
134
134
6.7
13.4
9,832
Assume
50%
of
performance
tests
require
a
retest.

Periodic
v.
Storage
vessels
­

annual
inspections
3
9
27
134
3,618
180.9
361.8
265,471
annual
­
9
vessels
per
respondent,

three
hours
per
tank
per
year
vi.
Equipment
leaks
­

monitoring
This
estimate
does
not
include
the
monitoring
of
Table
1:
Annual
Respondent
Burden
and
Cost,
NESHAP
for
Petroleum
Refineries
(
40
CFR
Part
63,
Subpart
CC),
Continued
19
Activity
Technical
Hrs/
Occurrence
(
A)
Occurrences
/
Respondent
/
Yr.

(
B)
Hours/
Respondent/

Yr.

(
C)

(
C
=
A
x
B)
#
Respondents
(
D)
Technical
Hrs/
Yr.

(
E)

(
E
=
C
x
D)
Management
Hours/
Yr.

(
F)

(
F
=
0.05
x
E)
Clerical
Hours/

Yr.

(
G)

(
G
=
0.1
x
E)
Total
Labor
Costs/
Yr.
($)

(
H)
1
Assumptions
equipment
leak
components.
The
cost
for
monitoring
equipment
leak
components
is
included
as
part
of
the
cost
of
the
leak
detection
and
repair
program,
which
is
a
requirement
of
the
regulation.

vii.
Process
vents
­

monitoring
1
24
24
134
3,216
160.8
321.6
235,974
monthly
­
one
hour
per
control
device,

two
monitored
devices,
12
months
per
year
C.
Create
information
See
3B
D.
Gather
existing
information
See
3E
E.
Write
reports
Initial
i.
Notification
of
Compliance
Status
­

Group
1
storage
vessels
1
0.9
0.9
134
120.6
6.03
12.06
8,849
1
hr/
Group
1
vessel,
9
vessels,

10%
reconstructed
ii.
Notification
of
4
1.1
4.4
134
589.6
29.48
58.96
43,262
4
hrs/
unit,
11
units,
Table
1:
Annual
Respondent
Burden
and
Cost,
NESHAP
for
Petroleum
Refineries
(
40
CFR
Part
63,
Subpart
CC),
Continued
20
Activity
Technical
Hrs/
Occurrence
(
A)
Occurrences
/
Respondent
/
Yr.

(
B)
Hours/
Respondent/

Yr.

(
C)

(
C
=
A
x
B)
#
Respondents
(
D)
Technical
Hrs/
Yr.

(
E)

(
E
=
C
x
D)
Management
Hours/
Yr.

(
F)

(
F
=
0.05
x
E)
Clerical
Hours/

Yr.

(
G)

(
G
=
0.1
x
E)
Total
Labor
Costs/
Yr.
($)

(
H)
1
Assumptions
Compliance
Status
­

equipment
leaks
10%
reconstructed
iii.
Notification
of
Compliance
Status
­

Group
1
process
vents
1
0.9
0.9
134
120.6
6.03
12.06
8,849
1
hr/
Group
1
vent,

9
vents,
10%
reconstructed
iv.
Notification
of
storage
vessel
inspection
1
0.9
0.9
134
120.6
6.03
12.06
8,849
1
hr/
vessel,
9
vessels,
10%
reconstructed
v.
Notification
of
process
vent
control
device
test
4
0.4
1.6
134
214.4
10.72
21.44
15,732
4
hrs/
notification,
2
notifications
per
test
(
two
dates),
2
controls,
10%
of
controls
reconstructed
and
tested
Periodic
vi.
Semiannual
reports
­

overall
18
2
36
134
4,824
241.2
482.4
353,961
vii.
Semiannual
reports
­

storage
vessels
1
18
18
134
2,412
120.6
241.2
176,981
1
hr/
vessel,
9
vessels,
twice
yearly
viii.
Semiannual
reports
­
storage
vessel
seal
gap
failure
3
2
6
134
804
40.2
80.4
58,994
3
hrs/
failure,
1
failure
per
report,

twice
yearly
ix.
Semiannual
reports
­
3
22
66
134
8,844
442.2
884.4
648,929
3
hours
per
unit,
11
Table
1:
Annual
Respondent
Burden
and
Cost,
NESHAP
for
Petroleum
Refineries
(
40
CFR
Part
63,
Subpart
CC),
Continued
21
Activity
Technical
Hrs/
Occurrence
(
A)
Occurrences
/
Respondent
/
Yr.

(
B)
Hours/
Respondent/

Yr.

(
C)

(
C
=
A
x
B)
#
Respondents
(
D)
Technical
Hrs/
Yr.

(
E)

(
E
=
C
x
D)
Management
Hours/
Yr.

(
F)

(
F
=
0.05
x
E)
Clerical
Hours/

Yr.

(
G)

(
G
=
0.1
x
E)
Total
Labor
Costs/
Yr.
($)

(
H)
1
Assumptions
equipment
leaks
units,
twice
yearly
x.
Semiannual
reports
­

process
vents
1.5
4
6
134
804
40.2
80.4
58,994
1.5
hours
per
control
device,
two
monitored
devices,

twice
yearly
xi.
Results
of
performance
test
See
3B
4.
Recordkeeping
Requirements
A.
Read
instructions
See
3A
B.
Plan
activities
Initial
i.
Applicability/
general
recordkeeping
and
reporting
10
1
10
134
1,340
67
134
98,323
Assume
10%
of
vessels/
units/
vents
are
reconstructed
each
year.
(
9
vessels,
11
units,
9
vents)
­
8
hrs/
vessel
initial.
6
hrs/
unit
initial,
2
hrs/
vent
initial
ii.
Storage
vessels
8
0.9
7.2
134
964.8
48.24
96.48
70,792
iii.
Equipment
leaks
6
1.1
6.6
134
884.4
44.22
88.44
64,893
iv.
Process
vents
2
0.9
1.8
134
241.2
12.06
24.12
17,698
Periodic
Table
1:
Annual
Respondent
Burden
and
Cost,
NESHAP
for
Petroleum
Refineries
(
40
CFR
Part
63,
Subpart
CC),
Continued
22
Activity
Technical
Hrs/
Occurrence
(
A)
Occurrences
/
Respondent
/
Yr.

(
B)
Hours/
Respondent/

Yr.

(
C)

(
C
=
A
x
B)
#
Respondents
(
D)
Technical
Hrs/
Yr.

(
E)

(
E
=
C
x
D)
Management
Hours/
Yr.

(
F)

(
F
=
0.05
x
E)
Clerical
Hours/

Yr.

(
G)

(
G
=
0.1
x
E)
Total
Labor
Costs/
Yr.
($)

(
H)
1
Assumptions
v.
Applicability/
general
recordkeeping
and
reporting
3
2
6
134
804
40.2
80.4
58,994
semiannual
vi.
Storage
vessels
1
9
9
134
1,206
60.3
120.6
88,490
annual
­
9
vessels
per
respondent,
one
hour
per
tank
per
year
vii.
Equipment
leaks
1
11
11
134
1,474
73.7
147.4
108,155
annual
­
11
units
per
respondent,
one
hour
per
unit
per
year
viii.
Process
vents
1
9
9
134
1,206
60.3
120.6
88,490
annual
­
9
vents
per
respondent,
one
hour
per
vent
per
year
C.
Implement
activities
Not
applicable
D.
Develop
record
system
Initial
i.
Storage
vessels
2
0.9
1.8
134
241.2
12.06
24.12
17,698
2
hrs/
vessel,
9
vessels,
10%
reconstructed
ii.
Equipment
leaks
75
1.1
82.5
134
11,055
552.75
1,105.5
811,161
75
hrs/
unit,
11
units,
10%
reconstructed
iii.
Process
vents
2
0.9
1.8
134
241.2
12.06
24.12
17,698
2
hrs/
vent,
9
vents,
Table
1:
Annual
Respondent
Burden
and
Cost,
NESHAP
for
Petroleum
Refineries
(
40
CFR
Part
63,
Subpart
CC),
Continued
23
Activity
Technical
Hrs/
Occurrence
(
A)
Occurrences
/
Respondent
/
Yr.

(
B)
Hours/
Respondent/

Yr.

(
C)

(
C
=
A
x
B)
#
Respondents
(
D)
Technical
Hrs/
Yr.

(
E)

(
E
=
C
x
D)
Management
Hours/
Yr.

(
F)

(
F
=
0.05
x
E)
Clerical
Hours/

Yr.

(
G)

(
G
=
0.1
x
E)
Total
Labor
Costs/
Yr.
($)

(
H)
1
Assumptions
10%
reconstructed
Periodic
iv.
Storage
vessels
2
18
36
134
4,824
241.2
482.4
353,961
semiannual
­
9
vessels
per
respondent,
two
hours
per
period
v.
Equipment
leaks
75
11
825
134
110,550
5,527.5
11,055
8,111,606
annual
­
11
units
per
respondent,
75
hours
per
period
vi.
Process
vents
2
9
18
134
2,412
120.6
241.2
176,981
annual
­
9
vents
per
respondent,
2
hours
per
period
E.
Enter
information
Initial
i.
Storage
vessels
4
0.9
3.6
134
482.4
24.12
48.24
35,396
4
hrs
per
vessel,
9
vessels,
10%
reconstructed
ii.
Equipment
leaks
24
1.1
26.4
134
3,537.6
176.88
353.76
259,571
24
hrs
per
unit,
11
units,
10%
reconstructed
iii.
Process
vents
12
0.2
2.4
134
321.6
16.08
32.16
23,597
12
hrs
per
control,

2
controls,
10%
reconstructed
Periodic
Table
1:
Annual
Respondent
Burden
and
Cost,
NESHAP
for
Petroleum
Refineries
(
40
CFR
Part
63,
Subpart
CC),
Continued
24
Activity
Technical
Hrs/
Occurrence
(
A)
Occurrences
/
Respondent
/
Yr.

(
B)
Hours/
Respondent/

Yr.

(
C)

(
C
=
A
x
B)
#
Respondents
(
D)
Technical
Hrs/
Yr.

(
E)

(
E
=
C
x
D)
Management
Hours/
Yr.

(
F)

(
F
=
0.05
x
E)
Clerical
Hours/

Yr.

(
G)

(
G
=
0.1
x
E)
Total
Labor
Costs/
Yr.
($)

(
H)
1
Assumptions
iv.
Storage
vessels
1.5
18
27
134
3,618
180.9
361.8
265,471
semiannual
­
9
vessels
per
respondent,
1.5
hours
per
vessel
per
period
v.
Equipment
leaks
2
132
264
134
35,376
1,768.8
3,537.6
2,595,714
monthly
­
11
units
per
respondent,
2
hours
per
unit
per
period
vi.
Process
vents
0.08
700
56
134
7,504
375.2
750.4
550,606
daily
(
350
days)
­
5
minutes
per
control
device,
two
monitored
devices
F.
Train
personnel
Initial
i.
Storage
vessels
1
0.9
0.9
134
120.6
6.03
12.06
8,849
Assume
10%
of
vessels/
units/
vents
are
reconstructed
each
year.
(
9
vessels,
11
units,
4
vents
with
controls)

1
hr
each
initial
ii.
Equipment
leaks
1
1.1
1.1
134
147.4
7.37
14.74
10,815
iii.
Process
vents
1
0.4
0.4
134
53.6
2.68
5.36
3,933
Periodic
Table
1:
Annual
Respondent
Burden
and
Cost,
NESHAP
for
Petroleum
Refineries
(
40
CFR
Part
63,
Subpart
CC),
Continued
25
Activity
Technical
Hrs/
Occurrence
(
A)
Occurrences
/
Respondent
/
Yr.

(
B)
Hours/
Respondent/

Yr.

(
C)

(
C
=
A
x
B)
#
Respondents
(
D)
Technical
Hrs/
Yr.

(
E)

(
E
=
C
x
D)
Management
Hours/
Yr.

(
F)

(
F
=
0.05
x
E)
Clerical
Hours/

Yr.

(
G)

(
G
=
0.1
x
E)
Total
Labor
Costs/
Yr.
($)

(
H)
1
Assumptions
iv.
Equipment
leaks
0.5
11
5.5
134
737
36.85
73.7
54,077
0.5
hours
per
year,

11
units
v.
Process
vents
1
4
4
134
536
26.8
53.6
39,329
4
out
of
9
vents
vent
to
controls.
1
hour
per
year,
4
vents
G.
Perform
audits
Not
applicable
H.
Record
and
disclose
information
Initial
i.
Storage
vessels
2
0.9
1.8
134
241.2
12.06
24.12
17,698
2
hrs
per
vessel,
9
vessels,
10%
reconstructed
ii.
Equipment
leaks
­

address
enforcement
actions
75
1.1
82.5
134
11,055
552.75
1,105.5
811,161
75
hrs/
unit,
11
units,
10%
reconstructed
Periodic
iii.
Storage
vessels
2
18
36
134
4,824
241.2
482.4
353,961
semiannual
­
9
vessels
per
respondent,
two
hours
per
vessel
iv.
Equipment
leaks
­

address
enforcement
actions
75
11
825
134
110,550
5,527.5
11,055
8,111,606
annual
­
address
enforcement
actions
­
11
units
Table
1:
Annual
Respondent
Burden
and
Cost,
NESHAP
for
Petroleum
Refineries
(
40
CFR
Part
63,
Subpart
CC),
Continued
26
Activity
Technical
Hrs/
Occurrence
(
A)
Occurrences
/
Respondent
/
Yr.

(
B)
Hours/
Respondent/

Yr.

(
C)

(
C
=
A
x
B)
#
Respondents
(
D)
Technical
Hrs/
Yr.

(
E)

(
E
=
C
x
D)
Management
Hours/
Yr.

(
F)

(
F
=
0.05
x
E)
Clerical
Hours/

Yr.

(
G)

(
G
=
0.1
x
E)
Total
Labor
Costs/
Yr.
($)

(
H)
1
Assumptions
per
respondent,
75
hours
per
unit
v.
Process
vents
1
4
4
134
536
26.8
53.6
39,329
semiannual
­
one
hour
per
control
device,
two
monitored
devices
TOTAL
LABOR
BURDEN
AND
COST
(
rounded)
410,054
$
26,163,236
1
This
cost
is
based
on
the
sum
of
personnel
hours
multiplied
by
their
hourly
labor
rates
[(
Technical
hours
x
$
64.60)
+
(
Management
hours
x
$
95.32)
+
(
Clerical
hours
x
$
40.09)].
Notes/
assumptions:

°
9
storage
vessels
per
refinery
require
controls;

°
11
units
per
refinery
are
subject
to
equipment
leak
provisions;

°
9
process
vents
per
refinery
­
5
are
routed
to
fuel
gas
systems
(
which
do
not
require
performance
tests),
4
are
routed
to
control
devices
­
2
control
devices
require
testing
and
monitoring;

°
134
refineries
are
subject
to
MACT
Subpart
CC;

°
Refineries
construct
or
reconstruct
10%
of
affected
facilities
per
year;
and
°
Nearly
all
of
the
hour/
activity
estimates
are
from
the
previous
ICR.
27
Table
2:
Annual
Agency
Burden
and
Cost,
NESHAP
for
Petroleum
Refineries
(
40
CFR
Part
63,
Subpart
CC)

Activity
Technical
Hrs/
Occurrence
(
A)
Occurrences/

Respondent/

Yr.

(
B)
Hours/
Respondent/
Yr.

(
C)

(
C
=
A
x
B)
#
Respondents
(
D)
Technical
Hrs/
Yr.

(
E)

(
E
=
C
x
D)
Management
Hours/
Yr.

(
F)

(
F
=
0.05
x
E)
Clerical
Hours/
Yr.

(
G)

(
G
=
0.1
x
E)
Total
Labor
Costs/
Yr.

($)
(
H)
1
Assumptions
1.
Review
of
notification
of
construction/
reconstruction
1
1
1
67
67
3.35
6.7
3,048
Applies
only
to
process
vents
and
assumes
one
vent
per
source.
Assumes
that
50%
of
refineries
are
affected
by
the
requirement
per
year.

2.
Review
of
notification
of
actual
start­
up
1
1
1
67
67
3.35
6.7
3,048
Applies
only
to
process
vents
and
assumes
one
vent
per
source.
Assumes
that
50%
of
refineries
are
affected
by
the
requirement
per
year.

3.
Review
of
notification
of
performance
test
1
1
1
20
20
1
2
910
Assume
20
respondents
based
on
previous
ICR.

4.
Review
of
notification
of
compliance
status
10
1
10
134
1,340
67
134
60,954
5.
Review
of
semiannual
equipment
leak
reports
10
2
20
67
1,340
67
134
60,954
Assumes
50%
of
sources
affected
by
the
rule
are
already
submitting
reports
to
comply
with
existing
regulations.

6.
Review
of
semiannual
parameter
4
2
8
67
536
26.8
53.6
24,382
Assumes
50%
of
sources
affected
by
the
rule
are
Table
2:
Annual
Agency
Burden
and
Cost,
NESHAP
for
Petroleum
Refineries
(
40
CFR
Part
63,
Subpart
CC),
Continued
28
Activity
Technical
Hrs/
Occurrence
(
A)
Occurrences/

Respondent/

Yr.

(
B)
Hours/
Respondent/
Yr.

(
C)

(
C
=
A
x
B)
#
Respondents
(
D)
Technical
Hrs/
Yr.

(
E)

(
E
=
C
x
D)
Management
Hours/
Yr.

(
F)

(
F
=
0.05
x
E)
Clerical
Hours/
Yr.

(
G)

(
G
=
0.1
x
E)
Total
Labor
Costs/
Yr.

($)
(
H)
1
Assumptions
exceedance
reports
already
submitting
reports
to
comply
with
existing
regulations.
Assumes
parameter
monitoring
of
one
vent
per
refinery
and
one
exceedance
per
year.

7.
Review
of
annual
tank
inspection
failure
reports
4
1
4
67
268
13.4
26.8
12,191
Assumes
50%
of
sources
affected
by
the
rule
are
already
submitting
reports
to
comply
with
existing
regulations.

TOTAL
LABOR
BURDEN
AND
COST
(
rounded)
4,184
$
165,485
1
This
cost
is
based
on
the
sum
of
personnel
hours
multiplied
by
their
hourly
labor
rates
[(
Technical
hours
x
$
40.56)
+
(
Management
hours
x
$
54.66)
+
(
Clerical
hours
x
$
21.95)].
29
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
Hours
Requested
is
shown
on
the
OMB
83­
I
form
in
block
13(
c).
The
total
annual
labor
costs
are
$
26,163,236.
The
annual
labor
costs
are
not
shown
on
the
OMB
83­
I
form.
Details
regarding
these
estimates
may
be
found
in
Table
1:
Annual
Respondent
Burden
and
Cost,
NESHAP
for
Petroleum
Refineries
(
40
CFR
part
63,
subpart
CC),
above.
Furthermore,
the
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
839
hours
per
response.

The
total
annual
capital/
startup
and
O&
M
costs
to
the
regulated
entity
are
$
0.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
14(
c),
Total
annualized
cost
requested.
The
cost
calculations
are
detailed
in
Section
6(
b)(
iii),
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs.

(
ii)
The
Agency
Tally
The
average
annual
Agency
burden
and
cost
over
next
three
years
is
estimated
to
be
4,184
labor
hours
at
a
cost
of
$
165,485.
See
Table
2:
Annual
Agency
Burden
and
Cost,
NESHAP
for
Petroleum
Refineries
(
40
CFR
part
63,
subpart
CC),
above.

6(
f)
Reasons
for
Change
in
Burden
The
decrease
in
burden
from
the
most
recently
approved
ICR
is
due
to
adjustments.
This
adjustment
decrease
in
burden
is
due
to
several
factors,
including:
a
decrease
in
the
number
of
respondents,
the
removal
of
capital/
startup
costs
resulting
from
performance
tests,
and
revisions
to
the
approach
to
calculating
costs
for
newly
subject
facilities.

The
most
recently
approved
ICR
considered
costs
from
performance
tests
to
be
capital/
startup
costs.
In
this
ICR,
the
burden
associated
with
performance
tests
has
not
been
included
in
the
estimate
for
capital/
startup
costs
because
these
costs
are
now
intended
to
include
only
nonlabor
burden.
The
hour
burden
associated
with
conducting
performance
tests
is
included
in
the
labor
burden
for
industry,
as
presented
in
Table
1:
Annual
Respondent
Burden
and
Cost,
NESHAP
for
Petroleum
Refineries
(
40
CFR
part
63,
subpart
CC),
above.

6(
g)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
839
hours
per
response.
Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
30
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.

An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
valid
OMB
Control
Number.
The
OMB
Control
Numbers
for
EPA's
regulations
are
listed
at
40
CFR
part
9
and
48
CFR
Chapter
15.

To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
Number
OECA­
2004­
0016,
which
is
available
for
public
viewing
at
the
Enforcement
and
Compliance
Docket
and
Information
Center
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Avenue,
NW,
Washington,
DC.
The
EPA
Docket
Center
Public
Reading
Room
is
open
from
8:
30
a.
m.
to
4:
30
p.
m.,
Monday
through
Friday,
excluding
legal
holidays.
The
telephone
number
for
the
Reading
Room
is
(
202)
566­
1744,
and
the
telephone
number
for
the
Enforcement
and
Compliance
Docket
and
Information
Center
is
(
202)
566­
1752.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
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,
NW,
Washington,
DC
20503,
Attention:
Desk
Officer
for
EPA.
Please
include
the
EPA
Docket
ID
Number
OECA­
2004­
0016
and
OMB
Control
Number
2060­
0340
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
