SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Petroleum Refineries, Catalytic Cracking, Reforming and
Sulfur Units (40 CFR Part 63, Subpart UUU) (Renewal)

1.  Identification of the Information Collection

1(a)  Title of the Information Collection

NESHAP for Petroleum Refineries, Catalytic Cracking, Reforming and
Sulfur Units (40 CFR Part 63, Subpart UUU) (Renewal), EPA ICR Number
1844.04, OMB Control Number 2060-0554

1(b)  Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP)
for Petroleum Refineries, Catalytic Cracking, Reforming and Sulfur Units
(40 CFR part 63, subpart UUU) were proposed on September 11, 1998,
promulgated on April 11, 2002, and amended on February 9, 2005.  These
regulations apply to three types of affected sources at major source
petroleum refineries.  The three affected sources are: the fluid
catalytic cracking unit catalyst regeneration; the catalytic reforming
unit catalyst regeneration; and the sulfur recovery unit.  The rule also
includes requirements for by-pass lines associated with the three
affected sources.  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 UUU.

The rule provides a wide variety of compliance and monitoring options. 
Depending on the affected source and compliance option, the rule may
require a continuous opacity monitoring system, a continuous emission
monitoring system, a continuous parameter monitoring system, manual
inspections, and/or calculations.  Continuous opacity monitoring systems
(COMS) and continuous emission monitoring systems (CEMS) are in-place at
a majority of the facilities due to the requirements of the New Source
Performance Standards (NSPS) for Petroleum Refineries (40 CFR part 60,
subpart J).

In general, all NESHAP standards require initial notifications,
performance tests, and periodic reports by the owners/operators of the
affected facilities.  They 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
affected facilities subject to NESHAP.  

Any owner/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.

Based on our consultations with industry representatives and AFS, we
have determined that 132 major petroleum refineries have one or ore
affected facilities subject to the standard.  Furthermore, we have
estimated that there is an average of 486 affected units at the 132
major source petroleum refineries.  No new or reconstructed facilities
are expected over the next 3 years.  However, it is estimated that three
affected emission source units had qualified for a compliance date
extension and would be complying with the initial compliance
requirements during the period of this ICR (one per year); and one
affected facility (0.33 per year) will conduct a performance test due to
a process/operating change.  The 132 respondents to this ICR are
publicly owned and operated by petroleum refineries.  None of the
facilities are owned by either state, local and tribal agencies or the
Federal Government. 

The burden to the “Affected Public” (i.e., major source petroleum
refineries) can be found below in Table 1: Annual Respondent Burden and
Cost: NESHAP for Petroleum Refineries, Catalytic Cracking, Reforming and
Sulfur Units (40 CFR Part 63, Subpart UUU) (Renewal).  The burden to the
“Federal government” is attributed entirely to work performed by
Federal employees or government contractors.  The burden to the Federal
government can be found below in Table 2: Annual Burden and Cost to the
Federal/State Government: NESHAP for Petroleum Refineries, Catalytic
Cracking, Reforming and Sulfur Units (40 CFR Part 63, Subpart UUU)
(Renewal).  

The Office of Management and Budget (OMB) approved the currently active
Information Collection Request (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/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, metal hazardous air pollutants (HAP)
and organic HAP emissions from catalytic cracking units; organic and
inorganic HAP emissions from catalytic reforming units; and HAP
emissions from sulfur recovery units and bypass lines, either 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 UUU.

2(b)  Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standards ensure
compliance with the applicable regulations which where promulgated in
accordance with the Clean Air Act.  The collected information is also
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 standards. 
Continuous emission monitors are used to ensure compliance with the
standards at all times.  During the performance test, 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 standards 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 and leaks are being detected and
repaired and the standards are being met.  The performance test may also
be observed.

The required semiannual reports are used to determine periods of excess
emissions, identify problems at the facility, verify
operation/maintenance procedures and for compliance determinations.

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

The requested recordkeeping and reporting are required under 40 CFR part
63, subpart UUU.

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 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.

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 (75 FR 30812) on June 2, 2010.  No
comments were received on the burden published in the Federal Register. 

3(c)  Consultations

	

	The assumptions made in the development of this ICR, including the
estimate on the number of petroleum refineries subject to the standard,
were reviewed and updated, if needed, by the Agency in consultation with
David Friedman of the National Petrochemical and Refiners Association
(NPRA) who consulted with some of its committee members.  In addition,
we consulted the Agency’s internal data sources including our own
industry experts and the Air Facility System (AFS), which is the EPA
database for the collection, maintenance, and retrieval of all
compliance data.  The information in AFS is reported by industry as
required in the recordkeeping and reporting provisions of the standard. 
AFS is operated and maintained by the EPA Office of Compliance.  We have
estimated that there are approximately 132 existing respondents subject
to the standard, and no new sources will become subject to the standard
over the three-year period covered by this ICR.

	The Agency also has the policy to respond after a thorough review of
the comments received from the public since the last ICR renewal, as
well as those submitted in response to the first Federal Register
notice.  In this case, no comments were received.

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 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 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 five years.  In addition, EPA would be
prevented from pursuing the violators due to the destruction or
nonexistence of essential records.

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
owners or operators of major source petroleum refineries.  The United
States Standard Industrial Classification (SIC) code for the respondents
affected by the standards is code 2911 which corresponds to the North
American Industry Classification System (NAICS) code 32411 for petroleum
refineries that operate catalytic cracking units, catalytic reforming
units, or sulfur recovery units.

4(b)  Information Requested 

(i)  Data Items

In this ICR, all the data that is recorded or reported is required by
the NESHAP for Petroleum Refineries, Catalytic Cracking, Reforming and
Sulfur Units (40 CFR Part 63, Subpart UUU). 

A source must make the following reports:

Notification Reports

Notification of intention to construct or reconstruct	63.9(b)(5),
63.1574(a) 

Notification of anticipated date of initial startup 	63.9(b)(4)(iv),
63.1574(a)

Notification of commencement of construction 	63.9(b)(4)(iii),
63.1574(a)

Notification of the actual date of startup	63.9(b)(4)(v), 63.1574(a)

Notification of performance tests 	63.7(a) and 63.9(e), 63.1574(a)

Notification of compliance status	63.9(g), 63.1574(d), (f)

Request for compliance extension	63.9(c), 63.1574(e)



Reports

Semiannual compliance reports 	63.10(e)(3), 63.1575

Startup, shutdown, and malfunction plan/reports 	63.6(3), 63.10(d)(5),
63.1570, 63.1575



A source must keep the following records:

Recordkeeping

Maintain records of startup, shutdown, and malfunction plan/reports
63.1576(a)(2), 63.10(b)(2)

Maintenance	63.10(b)(2)(iii), 63.1576(d)

CMS/CEM malfunction	63.1576(b), 63.10(c)

Emissions data	63.1576(a)(3), 63.10(d)

Notification of compliance status	63.1576(a)(1), 63.9(h)

CEM quality assurance plan	63.1576(b), 63.8(d)

CEM general provisions	63.1576(b), 63.10(c)

Records are required to be retained for 5 Years	63.10(c), 63.428(d)



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 still not widely used.  At this time,
it is estimated that approximately 10 percent of the respondents use
electronic reporting.

(ii)  Respondent Activities

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate CMS for opacity or emission
monitoring for catalytic cracking units, catalytic reforming units and
sulfur recovery systems. 

Perform initial performance test, Reference Method 5B or 5F (40 CFR Part
60) test for PM, 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.

Develop, acquire, install, and utilize technology and systems for the
purpose of disclosing and providing information.

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

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 might inspect
the source to determine whether 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 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 the AFS which is
operated and maintained by the EPA Office of Compliance.  AFS is the EPA
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 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 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.  A small entity for petroleum refineries is defined as a
firm having no more than 1,500 employees and no more than 75,000 barrels
per day capacity corporately.  Numerous compliance and monitoring
alternatives are provided in the rule to give small entities a maximum
degree of operational flexibility.  The rule requirements are considered
to be the minimum necessary to demonstrate compliance.

Under section 112(i) of the Clean Air Act, the Administrator or
applicable permitting authority also may grant one (1) additional year
if more time is needed to install controls for a source.  This
additional time will ease any capital availability problems for plants
in marginal economic condition.  The Agency expected three affected
units to qualify for the compliance extension. 

5(d)  Collection Schedule

The specific frequency for each information collection activity within
this request is shown below in Table 1: Annual Respondent Burden and
Cost: NESHAP for Petroleum Refineries, Catalytic Cracking, Reforming and
Sulfur Units (40 CFR Part 63, Subpart UUU) (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
each of the subparts 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.  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 11,040
( Total Labor Hours from Table 1).  The recordkeeping hours shown below
in Table 1 are 7,936.  The reporting requirement hours shown below in
Table 1 are 3,103.  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	$105.86 ($50.41 + 110%)  

Technical	$92.61   ($44.10 + 110%)

Clerical	$45.32   ($21.58 + 110%)

These rates are from the United States Department of Labor, Bureau of
Labor Statistics, December 2006, 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

The type of industry costs associated with the information collection
activities in the subject standards 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.  There is no capital cost for continuous
monitoring since we have assumed that all existing respondent have
installed the necessary equipment for monitoring and for file storage,
as described in the total of column D below.  The annual operation and
maintenance costs are the ongoing costs to maintain continuous emission
monitors (CEMS), continuous opacity monitors (COMS) and/or parametric
monitors (CPMS) at the affected facilities including: fuel catalytic
cracking units (FCCUs); catalytic reforming units (CRUs); sulfur
recovery units (SRUs); photocopying and postage, as described below.  We
have assumed that a respondent would monitor the affected emission units
either using a CEMS or CPMS. 

(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 Affected Facility	(C)

Number of New Affected Facilities	(D)

Total Capital/Startup Cost

(B X C)	(E)

Annual O&M Costs for One Affected Facility	(F)

Number of Affected Facilities with O&M	(G)

Total O&M,

(E X F)

COMS (FCCUs)	$95,700	0	$0.00	$28,600	13	371,800

CPMS (FCCUs)	$18,900	0	$0.00	$25,350	43	$1,090,050

CPMS (CRUs)	$0.00	0	$0.00	$24,056 *	132 	$3,175,392

CPMS (SRUs)	$74,000	0	$0.00	$26,000	84	$2,184,000

CEMS (SRUs)	$150, 000	0	$0.00	$34,840	29	$1,010,360

TOTAL

	$0.00

	$7,831,602

* Note: We estimate that there are 177 CRUs using CPMS for monitoring
(i.e., an average of 1.34 CRUs per respondent ) at a cost of $17,940 per
CPMS which total $24,056 per respondent.

The annual cost for capital/startup and operation and maintenance costs
to industry     over the next three years of the ICR are estimated to be
$7,831,602.  There are no capital costs  in the renewal of this ICR
since existing sources have already installed the necessary monitoring
equipment to comply with the standard, as described in the total of
column D, above.  The operation and maintenance costs to industry over
the next three years of the ICR are estimated to be $7,831,602, as
described in Column G, above.  We have determined that many of the FCCUs
and SRUs are now subject to the NSPS requirements and the associated
monitoring would not be attributed to this ICR. 

6(c)  Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of
the reported information.  The EPA compliance and enforcement program
includes activities such as: the review 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 $25,813 (see Table 2 below.)

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

	Managerial	$58.18  (GS-13, Step 5, $36.36 + 60%) 

	Technical	$43.17  (GS-12, Step 1, $26.98 + 60%)

	Clerical	$23.36  (GS-6, Step 3, $14.60 + 60%)

These rates are from the Office of Personnel Management (OPM) 2007
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 below in Table 2: Annual Burden and Cost to the
Federal/State Government: NESHAP for Petroleum Refineries, Catalytic
Cracking, Reforming and Sulfur Units (40 CFR Part 63, Subpart UUU)
(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 132 existing respondents will be subject to the
standard.  It is estimated that no additional respondents per year will
become subject to the standard.  However, it is estimated that three
affected emission source units had qualified for a compliance date
extension and would be complying with the initial compliance
requirements during the period of this ICR (one per year); and one
affected facility (0.33 per year) will conduct a performance test due to
a process/operating change.  The overall average number of respondents
per year subject to this standard is calculated using the following
table that 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 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	1.3	132	0	1.3	132

2	1.3	132	0	1.3	132

3	1.3	132	0	1.3	132

Average	1.3	132	0	1.3	132

1  New respondents include sources with constructed, reconstructed, and
modified affected facilities.  In this standard, existing respondents
submit initial notifications.

.

Column D is subtracted to avoid double-counting respondents.  As shown
above, the average Number of Respondents over the three-year period of
this ICR is 132.

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

Notification of performance test	1.33	1	0	1.33

Semiannual compliance report	2	132	0	264



	Total	265.33



The number of Total Annual Responses is 265 (rounded).  The total annual
labor costs are $983,339 (rounded).  Details regarding these estimates
may be found below in Table 1: Annual Respondent Burden and Cost: NESHAP
for Petroleum Refineries, Catalytic Cracking, Reforming and Sulfur Units
(40 CFR Part 63, Subpart UUU) (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 11,040.  Details regarding these
estimates may be found below in Table 1: Annual Respondent Burden and
Cost: NESHAP for Petroleum Refineries, Catalytic Cracking, Reforming and
Sulfur Units (40 CFR Part 63, Subpart UUU) (Renewal).  Furthermore, the
annual public reporting and recordkeeping burden for this collection of
information is estimated to average 42 hours (rounded) per response.

The total annual capital/startup and O&M costs to the regulated entity
are $7,831,602.  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 620 labor hours (rounded) at a cost of $25,813
(rounded).  See below Table 2: Annual Agency Burden and Cost: NESHAP for
Petroleum Refineries, Catalytic Cracking, Reforming and Sulfur Units (40
CFR Part 63, Subpart UUU) (Renewal).

6(f)  Reasons for Change in Burden

There is no change in the labor hours or cost to the respondents in this
ICR compared to the previous ICR.  This is due to two considerations: 1)
the regulations have not changed over the past three years and are not
anticipated to change over the next three years; and 2) the growth rate
for the respondents is very low, negative or non-existent.  Therefore,
the labor hours and cost figures in the previous ICR reflect the current
burden to the respondents and are reiterated in this ICR.  However,
there is a correction of a previous error in the calculation of the O&M
costs from $6,850,602 to $7,831,602.

6(g)  Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 42 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 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 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-2010-0375.  An electronic version of the public docket is
available at http://www.regulations.gov/ which may be used to obtain a
copy of the draft collection of information, submit or view public
comments, access the index listing of the contents of the 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 in this document.  The documents are
also available for public viewing at the Enforcement and Compliance
Docket and Information Center in the EPA Docket Center (EPA/DC), EPA
West, Room 3334, 1301 Constitution Avenue N.W., 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 docket center is (202) 566-1752.  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-2010-0375 and OMB Control Number 2060-0554 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: NESHAP for Petroleum
Refineries, Catalytic Cracking, Reforming and Sulfur Units (40 CFR Part
63, Subpart UUU) (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 person-hours per year

(E=CxD)	(F)

Management person-hours per year

(Ex0.05)	(G)

Clerical person- hours per year

(Ex0.1)	(H)

Cost,$ b

1. Applications	N/A







	2. Survey and Studies	N/A







	3. Acquisition, Installation, and

   Utilization of Technology and

   Systems  	40	1	40	0	0.0	0.0	0.0	$0.00

4. Reporting Requirements









A. Read instructions  c	2	1	2	1.33	2.7	0.1	0.3	$274.24

B. Required activities  c









  Initial Performance test  c 	40	1	40	1	40.0	2.0	4.0	$4,097.40

  Performance test  d  	40	1	40	0.33	13.2	0.7	1.3	$1,355.47

  Startup, shutdown, malfunction

  Plan	40	1	40	0	0.0	0.0	0.0	$0.00

  Operating, maintenance, and

  monitoring plan  b	40	1	40	0	0.0	0.0	0.0	$0.00

C. Create information	See 4B







	D. Gather existing information	See 4B







	E. Write report









  Notification of construction/ reconstruction	2	1	2	0	0.0	0.0	0.0	$0.00

  Notification of actual startup	2	1	2	0	0.0	0.0	0.0	$0.00

  Notification of special

  compliance requirements	N/A







	  Notification of performance

  test  b	2	1	2	1.33	2.7	0.1	0.3	$274.24

  Notification of compliance     

  Status  b	4	1	4	0	0.0	0.0	0.0	$0.00

  Extended compliance request  	N/A







	  Report of performance test   c 	See 4B







	  Semiannual compliance 

  reports  e	10	2	20	132	2,640.0	132.0	264.0	$270,428.40

5. Recordkeeping Requirements









A. Read instructions	See 4A







	B. Plan activities  c	See 4B







	C. Implement activities  c	See 4B







	D. Develop record system  f	N/A







	E. Time to enter information  g& h  









    Records of operations  	1	52	52	132	6,864.0	343.2	686.4	$703,113.84

F. Time to train personnel  	4	1	4	1	4	0.02	0.4	$409.74

G. Time to adjust existing ways to comply with previously applicable
requirements  	N/A







	H. Time to transmit or disclose

Information  b& i	0.25	1 	0.25	132	33.0	1.7	3.3	$3,385.65

I. Time for audits	N/A







	 Subtotal Labor Burden



	9,596.9	479.9	959.74	$983,338.98

TOTAL LABOR BURDEN AND COST



	11,040 (rounded)	$983,339



Assumptions:

a  We have determined that 132 major petroleum refineries operate have
one or more affected facilities subject to the standard.  Furthermore,
we have estimated that there is an average of 486 affected units at the
132 major source petroleum refineries.  No new or reconstructed
facilities are expected over the next 3 years. 

b  This ICR uses the following labor rates: $105.86 per hour for
Executive, Administrative, and Managerial labor; $92.61 per hour for
Technical labor, and $45.32 per hour for Clerical labor.  These rates
are from the United States Department of Labor, Bureau of Labor
Statistics, September 2006, ”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. 

c  We have assumed that all existing respondents (132 major source
petroleum refineries) over the 3-year term of this ICR have complied
with rule initial requirements including the initial performance test. 
However, it was estimated that three (3) affected units had qualified
for the compliance date extension due to installation of control
equipment and, therefore, would be complying with the initial
performance test during the period of this ICR (one per year).     

d  We have assumed that one respondent over the 3-year term of this ICR
will conduct a performance test due to significant process/operating
change 

(1/3 = 0.333).

e  All sources would be submitting semiannual compliance reports.

f  We have assumed that sources have the record system in place to
monitor operations. 

g  Depending on the compliance option for the affected facility (i.e.,
catalytic cracking unit, sulfur recovery units, and by-pass lines)
selected by the respondent and the size of the catalytic cracking unit
and control device used (e.g., wet scrubber, electrostatic precipitator
and thermal incinerators), sources are required to either installed
continuous opacity monitoring systems and/or continuous parameter
monitoring, or choose an alternative option for parameter monitoring.   


h  We have assumed that all respondents would have to keep records of
their operations according to the operation and maintenance plan.

i  We have assumed that it takes respondents approximate one hour to
record data per week (52 weeks) and 15 minutes to transmit it
semiannually.

N/A  Not applicable. 

Table 2.  Annual Burden and Cost to the Federal/State Government:
NESHAP for Petroleum Refineries, Catalytic Cracking, Reforming and
Sulfur Units (40 CFR Part 63, Subpart UUU) (Rounded) 

Activity	(A)Hours per occurrence	(B)

Hours per plant per year	(C)

Plants per year  	(D)

Technical person-hours per year

(D=BxC)	(E)

Management person-hours per year

(Dx0.05)	(F)

Clerical person-hours per year

(Dx0.1)	(G)

Cost, $ a

Report Review







	   Notification of construction/reconstruction	N/A







   Notification of actual startup	N/A







   Notification of special compliance 

   Requirements 	N/A







   Notification of initial performance test  b	2	2	1.33	2.7	0.1	0.3
$129.39

      Notification of performance test  c  	2	2	1.33	2.7	0.1	0.3	$129.39

   Notification of compliance status	2	2	0	0	0.0	0.0	$0.00

   Review of operation, maintenance, and

   monitoring plan  b 	4	4	0	0	0.0	0.0	$0.00

   Review of repeat performance test report	8	8	0	0	0.0	0.0	$0.00

   Review of compliance report	N/A







   Review of semiannual compliance reports d	2	4	132	528	26.4	52.8
$25,553.77

   Review of NESHAP waiver application	4	4	0	0.0	0.0	0.0	$0.00

   Subtotal Burden and Cost



533.4	26.6	53.8	$25,812.55

TOTAL BURDEN AND COST (SALARY)



614	$25,813



Assumptions:

a  This cost is based on the following labor rates:  Managerial rate of
$58.18 (GS-13, Step 5, $36.36 + 60%), Technical rate of $43.17 (GS-12,
Step 1, $26.98 + 60%), and Clerical rate of $23.36 (GS-6, Step 3, $14.60
+ 60%).  These rates are from the Office of Personnel Management (OPM)
(2007 General Schedule( which excludes locality rates of pay.  

b  We have assumed that all existing respondents (132 major source
petroleum refineries) over the 3-year term of this ICR have complied
with the rule initial requirements including the initial performance
test.  However, it was estimated that three (3) affected units had
qualified for the compliance date extension due to installation of
control equipment and, therefore, would be complying with the initial
performance test during the period of this ICR (one per year).   

c  We have assumed that one respondent over the 3-year term of this ICR
will conduct a performance test due to significant process/operating
change 

(1/3 = 0.333).

d  All sources would be submitting semiannual compliance reports.

N/A  Not applicable. 

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