|
|
|
Attachment 2 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Table 1 - Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements of the MACT Floor |
for Existing Sources: Polyvinyl Chloride and Copolymer Manufacturing Units - Year 1 |
|
|
|
|
(A) |
|
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
|
|
|
Footnotes |
|
|
|
|
Respondent |
Non-Labor |
Number of |
Hours |
Number of |
Technical |
Management |
Clerical |
Total |
Total |
Total |
|
|
|
|
Hours per |
Costs |
Occurrences |
Per |
Respondents |
Hours |
Hours |
Hours |
Labor Costs |
Non-Labor |
Responses |
|
|
|
|
Occurrence |
Per |
Per |
Respondent |
Per Year |
Per Year |
Per Year |
Per Year |
Per Year |
Costs |
Per Year |
|
|
|
|
(Technical |
Occurrence |
Respondent |
Per Year |
|
|
|
|
|
Per Year |
|
Burden Item |
hours) |
|
Per Year |
(C=A x B) |
|
(CXD) |
(E x 0.05) |
(E x 0.1) |
|
|
|
1. |
Applications |
|
|
N/A |
|
|
|
|
|
|
|
|
|
|
|
2. |
Surveys and Studies |
|
|
N/A |
|
|
|
|
|
|
|
|
|
|
|
3. |
Reporting Requirements |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
A. |
Read and Understand Rule Requirements |
|
25 |
$100 |
1 |
25 |
17 |
425 |
21 |
43 |
$46,229 |
$1,700 |
0 |
a,b |
|
B. |
Required Activities |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
1) Initial performance test, sampling, and report |
|
40 |
$53,139 |
1 |
40 |
17 |
680 |
34 |
68 |
$73,966 |
$903,355 |
0 |
a |
|
|
2) Periodic performance test, sampling, and report |
|
15 |
$54,042 |
1 |
15 |
17 |
255 |
13 |
26 |
$27,737 |
$918,716 |
0 |
f |
|
|
3) Establish operating parameters and monitoring plan |
|
20 |
$0 |
1 |
20 |
17 |
340 |
17 |
34 |
$36,983 |
$0 |
0 |
a |
|
|
4) Continuous parameter monitoring |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
a) Initial capital costs (Fabric Filters) |
0 |
$17,100 |
1 |
0 |
5 |
0 |
0 |
0 |
$0 |
$85,500 |
0 |
a,d |
|
|
|
b) Annualized capital and O&M costs (Fabric Filters & ACI) |
11 |
$31,700 |
1 |
11 |
5 |
55 |
3 |
6 |
$5,983 |
$158,500 |
0 |
c,e |
|
|
|
c) Initial capital costs (PRD Electronic Monitor) |
0 |
$188,913 |
1 |
0 |
17 |
0 |
0 |
0 |
$0 |
$3,211,521 |
0 |
a,d |
|
|
|
d) Annualized capital and O&M costs (PRD Electronic Monitor) |
11 |
$26,897 |
1 |
11 |
17 |
187 |
9 |
19 |
$20,341 |
$457,249 |
0 |
c,e |
|
|
|
e) Initial capital costs (PB Scrubber Monitor) |
0 |
$23,000 |
1 |
0 |
1 |
0 |
0 |
0 |
$0 |
$23,000 |
0 |
a,d |
|
|
|
f) Annualized capital and O&M costs (PB Scrubber Monitor |
11 |
$5,300 |
1 |
11 |
1 |
11 |
1 |
1 |
$1,197 |
$5,300 |
0 |
c,e |
|
C. |
Create Information |
|
Incl. in 3.B |
|
|
|
|
|
|
|
|
|
|
|
|
D. |
Gather Information |
|
Incl. in 3.E |
|
|
|
|
|
|
|
|
|
|
|
|
E. |
Report Preparation |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
1) Initial Notification |
|
5 |
$0 |
1 |
5 |
17 |
85 |
4 |
9 |
$9,246 |
$0 |
17 |
|
|
|
2) Batch precompliance report |
|
5 |
$0 |
1 |
5 |
17 |
85 |
4 |
9 |
$9,246 |
$0 |
17 |
|
|
|
3) Notification of performance test with test plan |
|
10 |
$0 |
1 |
10 |
17 |
170 |
9 |
17 |
$18,492 |
$0 |
17 |
|
|
|
4) Notification of compliance status |
|
20 |
$0 |
1 |
20 |
17 |
340 |
17 |
34 |
$36,983 |
$0 |
17 |
b |
|
|
5) Compliance report |
|
25 |
$0 |
1 |
25 |
0 |
0 |
0 |
0 |
$0 |
$0 |
0 |
|
|
|
6) Notice of inspection |
|
5 |
$0 |
1 |
5 |
17 |
85 |
4 |
9 |
$9,246 |
$0 |
17 |
|
|
|
7) Affirmative defense |
|
18 |
$0 |
1 |
18 |
0 |
18 |
12 |
0 |
$0 |
$0 |
0 |
g |
ReportingSubtotal |
|
|
|
|
|
|
|
|
2,718 |
136 |
272 |
$295,647 |
$2,444,820 |
85 |
|
4. Recordkeeping Requirements |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
A. Read Instructions |
|
|
Incl. in 3.A |
|
|
|
|
|
|
|
|
|
|
|
|
B. Implement Activities |
|
|
N/A |
|
|
|
|
|
|
|
|
|
|
|
|
C. Develop Record System |
|
|
N/A |
|
|
|
|
|
|
|
|
|
|
|
|
D. Record Information |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
1) Records of process vent requirements |
|
10 |
$0 |
1 |
10 |
0 |
0 |
0 |
0 |
$0 |
$0 |
0 |
|
|
|
2) Records of resin stripper and wastewater requirements |
|
15 |
$0 |
1 |
15 |
0 |
0 |
0 |
0 |
$0 |
$0 |
0 |
|
|
|
3) Records of storage vessel requirements |
|
10 |
$0 |
1 |
10 |
0 |
0 |
0 |
0 |
$0 |
$0 |
0 |
|
|
|
4) Records of equipment leak requirements |
|
25 |
$0 |
1 |
25 |
0 |
0 |
0 |
0 |
$0 |
$0 |
0 |
|
|
|
5) Records of heat exchanger requirements |
|
10 |
$0 |
1 |
10 |
0 |
0 |
0 |
0 |
$0 |
$0 |
0 |
|
|
E. Personnel Training |
|
|
Incl. in 3.B |
|
|
|
|
|
|
|
|
|
|
|
|
F. Time for Audits |
|
|
N/A |
|
|
|
|
|
|
|
|
|
|
|
Recordkeeping Subtotal |
|
|
|
|
|
|
|
|
0 |
0 |
0 |
$0 |
$0 |
0 |
|
TOTAL: |
|
|
|
|
|
|
|
|
2,718 |
136 |
272 |
$295,647 |
$2,444,820 |
85 |
|
|
|
|
|
|
|
|
|
|
|
Total Hours |
Labor |
Non-Labor |
Total |
|
|
|
|
|
|
|
|
|
Summary of Respondent Burden |
|
|
3,126 |
$295,647 |
$2,444,820 |
$2,740,467 |
|
|
|
|
|
|
|
|
|
Initial Capital and Startup |
|
|
|
|
$3,298,721 |
|
|
|
|
|
|
|
|
|
|
Annualized Capital/Start-up and O & M |
|
$2,444,820 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
FOOTNOTES |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
a |
One-time only costs. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
b |
Cost incurred by a facility regardless of the number of affected units at the plant. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
c |
Annual cost. Annual costs are not incurred until the second year of operation. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
d |
Based on the sum of the total capital costs for each monitoring system required for PVC facilities. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
e |
Based on the sum of the annualized capital costs for each monitoring system required for PVC facilities. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
f |
Includes 11 months testing for wastewater and resin to cover rest of the year after the initial test. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
g |
Hours for affirmative defense are shown only for illustration and are not included in the total burden estimate |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Attachment 2 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Table 2 - Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements of the MACT Floor |
for Existing Sources: Polyvinyl Chloride and Copolymer Manufacturing Units - Year 2 |
|
|
|
|
(A) |
|
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
|
|
|
Footnotes |
|
|
|
|
Respondent |
Non-Labor |
Number of |
Hours |
Number of |
Technical |
Management |
Clerical |
Total |
Total |
Total |
|
|
|
|
Hours per |
Costs |
Occurrences |
Per |
Respondents |
Hours |
Hours |
Hours |
Labor Costs |
Non-Labor |
Responses |
|
|
|
|
Occurrence |
Per |
Per |
Respondent |
Per Year |
Per Year |
Per Year |
Per Year |
Per Year |
Costs |
Per Year |
|
|
|
|
(Technical |
Occurrence |
Respondent |
Per Year |
|
|
|
|
|
Per Year |
|
Burden Item |
hours) |
|
Per Year |
(C=A x B) |
|
(CXD) |
(E x 0.05) |
(E x 0.1) |
|
|
|
1. |
Applications |
|
|
N/A |
|
|
|
|
|
|
|
|
|
|
|
2. |
Surveys and Studies |
|
|
N/A |
|
|
|
|
|
|
|
|
|
|
|
3. |
Reporting Requirements |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
A. |
Read and Understand Rule Requirements |
|
25 |
$100 |
1 |
25 |
0 |
0 |
0 |
0 |
$0 |
$0 |
0 |
a,b |
|
B. |
Required Activities |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
1) Initial performance test, sampling, and report |
|
40 |
$53,139 |
1 |
40 |
0 |
0 |
0 |
0 |
$0 |
$0 |
0 |
a |
|
|
2) Periodic performance test, sampling, and report |
|
50 |
$108,750 |
1 |
50 |
17 |
850 |
43 |
85 |
$92,458 |
$1,848,751 |
0 |
|
|
|
3) Establish operating parameters and monitoring plan |
|
20 |
$0 |
1 |
20 |
0 |
0 |
0 |
0 |
$0 |
$0 |
0 |
a |
|
|
4) Continuous parameter monitoring |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
a) Initial capital costs (Fabric Filters) |
0 |
$0 |
1 |
0 |
0 |
0 |
0 |
0 |
$0 |
$0 |
0 |
a,d |
|
|
|
b) Annualized capital and O&M costs (Fabric Filters & ACI) |
11 |
$31,700 |
1 |
11 |
5 |
55 |
3 |
6 |
$5,983 |
$158,500 |
0 |
c,e |
|
|
|
c) Initial capital costs (PRD Electronic Monitor) |
0 |
$0 |
1 |
0 |
0 |
0 |
0 |
0 |
$0 |
$0 |
0 |
a,d |
|
|
|
d) Annualized capital and O&M costs (PRD Electronic Monitor) |
11 |
$26,897 |
1 |
11 |
17 |
187 |
9 |
19 |
$20,341 |
$457,249 |
0 |
c,e |
|
|
|
e) Initial capital costs (PB Scrubber Monitor) |
0 |
$0 |
1 |
0 |
0 |
0 |
0 |
0 |
$0 |
$0 |
0 |
a,d |
|
|
|
f) Annualized capital and O&M costs (PB Scrubber Monitor |
11 |
$5,300 |
1 |
11 |
1 |
11 |
1 |
1 |
$1,197 |
$5,300 |
0 |
c,e |
|
C. |
Create Information |
|
Incl. in 3.B |
|
|
|
|
|
|
|
|
|
|
|
|
D. |
Gather Information |
|
Incl. in 3.E |
|
|
|
|
|
|
|
|
|
|
|
|
E. |
Report Preparation |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
1) Initial Notification |
|
5 |
$0 |
1 |
5 |
0 |
0 |
0 |
0 |
$0 |
$0 |
0 |
|
|
|
2) Batch precompliance report |
|
5 |
$0 |
1 |
5 |
0 |
0 |
0 |
0 |
$0 |
$0 |
0 |
|
|
|
3) Notification of performance test with test plan |
|
10 |
$0 |
1 |
10 |
0 |
0 |
0 |
0 |
$0 |
$0 |
0 |
|
|
|
4) Notification of compliance status |
|
20 |
$0 |
1 |
20 |
0 |
0 |
0 |
0 |
$0 |
$0 |
0 |
b |
|
|
5) Compliance report |
|
25 |
$0 |
1 |
25 |
17 |
425 |
21 |
43 |
$46,229 |
$0 |
17 |
|
|
|
6) Notice of inspection |
|
5 |
$0 |
1 |
5 |
17 |
85 |
4 |
9 |
$9,246 |
$0 |
17 |
|
|
|
7) Affirmative defense |
|
18 |
$0 |
1 |
18 |
0 |
18 |
12 |
0 |
$0 |
$0 |
0 |
f |
ReportingSubtotal |
|
|
|
|
|
|
|
|
1,613 |
81 |
161 |
$175,452 |
$2,469,800 |
34 |
|
4. Recordkeeping Requirements |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
A. Read Instructions |
|
|
Incl. in 3.A |
|
|
|
|
|
|
|
|
|
|
|
|
B. Implement Activities |
|
|
N/A |
|
|
|
|
|
|
|
|
|
|
|
|
C. Develop Record System |
|
|
N/A |
|
|
|
|
|
|
|
|
|
|
|
|
D. Record Information |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
1) Records of process vent requirements |
|
10 |
$0 |
1 |
10 |
17 |
170 |
9 |
17 |
$18,492 |
$0 |
0 |
|
|
|
2) Records of resin stripper and wastewater requirements |
|
15 |
$0 |
1 |
15 |
17 |
255 |
13 |
26 |
$27,737 |
$0 |
0 |
|
|
|
3) Records of storage vessel requirements |
|
10 |
$0 |
1 |
10 |
17 |
170 |
9 |
17 |
$18,492 |
$0 |
0 |
|
|
|
4) Records of equipment leak requirements |
|
25 |
$0 |
1 |
25 |
17 |
425 |
21 |
43 |
$46,229 |
$0 |
0 |
|
|
|
5) Records of heat exchanger requirements |
|
10 |
$0 |
1 |
10 |
17 |
170 |
9 |
17 |
$18,492 |
$0 |
0 |
|
|
E. Personnel Training |
|
|
Incl. in 3.B |
|
|
|
|
|
|
|
|
|
|
|
|
F. Time for Audits |
|
|
N/A |
|
|
|
|
|
|
|
|
|
|
|
Recordkeeping Subtotal |
|
|
|
|
|
|
|
|
1190 |
59.5 |
119 |
$129,441 |
$0 |
0 |
|
TOTAL: |
|
|
|
|
|
|
|
|
2,803 |
140 |
280 |
$304,893 |
$2,469,800 |
34 |
|
|
|
|
|
|
|
|
|
|
|
Total Hours |
Labor |
Non-Labor |
Total |
|
|
|
|
|
|
|
|
|
Summary of Respondent Burden |
|
|
3,223 |
$304,893 |
$2,469,800 |
$2,774,693 |
|
|
|
|
|
|
|
|
|
Initial Capital and Startup |
|
|
|
|
$0 |
|
|
|
|
|
|
|
|
|
|
Annualized Capital/Start-up and O & M |
|
$2,469,800 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
FOOTNOTES |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
a |
One-time only costs. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
b |
Cost incurred by a facility regardless of the number of affected units at the plant. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
c |
Annual cost. Annual costs are not incurred until the second year of operation. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
d |
Based on the sum of the total capital costs for each monitoring system required for PVC facilities. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
e |
Based on the sum of the annualized capital costs for each monitoring system required for PVC facilities. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
f |
Hours for affirmative defense are shown only for illustration and are not included in the total burden estimate |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Attachment 2 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Table 3 - Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements of the MACT Floor |
for Existing Sources: Polyvinyl Chloride and Copolymer Manufacturing Units - Year 3 |
|
|
|
|
(A) |
|
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
|
|
|
Footnotes |
|
|
|
|
Respondent |
Non-Labor |
Number of |
Hours |
Number of |
Technical |
Management |
Clerical |
Total |
Total |
Total |
|
|
|
|
Hours per |
Costs |
Occurrences |
Per |
Respondents |
Hours |
Hours |
Hours |
Labor Costs |
Non-Labor |
Responses |
|
|
|
|
Occurrence |
Per |
Per |
Respondent |
Per Year |
Per Year |
Per Year |
Per Year |
Per Year |
Costs |
Per Year |
|
|
|
|
(Technical |
Occurrence |
Respondent |
Per Year |
|
|
|
|
|
Per Year |
|
Burden Item |
hours) |
|
Per Year |
(C=A x B) |
|
(CXD) |
(E x 0.05) |
(E x 0.1) |
|
|
|
1. |
Applications |
|
|
N/A |
|
|
|
|
|
|
|
|
|
|
|
2. |
Surveys and Studies |
|
|
N/A |
|
|
|
|
|
|
|
|
|
|
|
3. |
Reporting Requirements |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
A. |
Read and Understand Rule Requirements |
|
25 |
$100 |
1 |
25 |
0 |
0 |
0 |
0 |
$0 |
$0 |
0 |
a,b |
|
B. |
Required Activities |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
1) Initial performance test, sampling, and report |
|
40 |
$53,139 |
1 |
40 |
0 |
0 |
0 |
0 |
$0 |
$0 |
0 |
a |
|
|
2) Periodic performance test, sampling, and report |
|
50 |
$108,750 |
1 |
50 |
17 |
850 |
43 |
85 |
$92,458 |
$1,848,751 |
0 |
|
|
|
3) Establish operating parameters and monitoring plan |
|
20 |
$0 |
1 |
20 |
0 |
0 |
0 |
0 |
$0 |
$0 |
0 |
a |
|
|
4) Continuous parameter monitoring |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
a) Initial capital costs (Fabric Filters) |
0 |
$0 |
1 |
0 |
0 |
0 |
0 |
0 |
$0 |
$0 |
0 |
a,d |
|
|
|
b) Annualized capital and O&M costs (Fabric Filters & ACI) |
11 |
$31,700 |
1 |
11 |
5 |
55 |
3 |
6 |
$5,983 |
$158,500 |
0 |
c,e |
|
|
|
c) Initial capital costs (PRD Electronic Monitor) |
0 |
$0 |
1 |
0 |
0 |
0 |
0 |
0 |
$0 |
$0 |
0 |
a,d |
|
|
|
d) Annualized capital and O&M costs (PRD Electronic Monitor) |
11 |
$26,897 |
1 |
11 |
17 |
187 |
9 |
19 |
$20,341 |
$457,249 |
0 |
c,e |
|
|
|
e) Initial capital costs (PB Scrubber Monitor) |
0 |
$0 |
1 |
0 |
0 |
0 |
0 |
0 |
$0 |
$0 |
0 |
a,d |
|
|
|
f) Annualized capital and O&M costs (PB Scrubber Monitor |
11 |
$5,300 |
1 |
11 |
1 |
11 |
1 |
1 |
$1,197 |
$5,300 |
0 |
c,e |
|
C. |
Create Information |
|
Incl. in 3.B |
|
|
|
|
|
|
|
|
|
|
|
|
D. |
Gather Information |
|
Incl. in 3.E |
|
|
|
|
|
|
|
|
|
|
|
|
E. |
Report Preparation |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
1) Initial Notification |
|
5 |
$0 |
1 |
5 |
0 |
0 |
0 |
0 |
$0 |
$0 |
0 |
|
|
|
2) Batch precompliance report |
|
5 |
$0 |
1 |
5 |
0 |
0 |
0 |
0 |
$0 |
$0 |
0 |
|
|
|
3) Notification of performance test with test plan |
|
10 |
$0 |
1 |
10 |
0 |
0 |
0 |
0 |
$0 |
$0 |
0 |
|
|
|
4) Notification of compliance status |
|
20 |
$0 |
1 |
20 |
0 |
0 |
0 |
0 |
$0 |
$0 |
0 |
b |
|
|
5) Compliance report |
|
25 |
$0 |
1 |
25 |
17 |
425 |
21 |
43 |
$46,229 |
$0 |
17 |
|
|
|
6) Notice of inspection |
|
5 |
$0 |
1 |
5 |
17 |
85 |
4 |
9 |
$9,246 |
$0 |
17 |
|
|
|
7) Affirmative defense |
|
18 |
$0 |
1 |
18 |
0 |
18 |
12 |
0 |
$0 |
$0 |
0 |
f |
ReportingSubtotal |
|
|
|
|
|
|
|
|
1,613 |
81 |
161 |
$175,452 |
$2,469,800 |
34 |
|
4. Recordkeeping Requirements |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
A. Read Instructions |
|
|
Incl. in 3.A |
|
|
|
|
|
|
|
|
|
|
|
|
B. Implement Activities |
|
|
N/A |
|
|
|
|
|
|
|
|
|
|
|
|
C. Develop Record System |
|
|
N/A |
|
|
|
|
|
|
|
|
|
|
|
|
D. Record Information |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
1) Records of process vent requirements |
|
10 |
$0 |
1 |
10 |
17 |
170 |
9 |
17 |
$18,492 |
$0 |
0 |
|
|
|
2) Records of resin stripper and wastewater requirements |
|
15 |
$0 |
1 |
15 |
17 |
255 |
13 |
26 |
$27,737 |
$0 |
0 |
|
|
|
3) Records of storage vessel requirements |
|
10 |
$0 |
1 |
10 |
17 |
170 |
9 |
17 |
$18,492 |
$0 |
0 |
|
|
|
4) Records of equipment leak requirements |
|
25 |
$0 |
1 |
25 |
17 |
425 |
21 |
43 |
$46,229 |
$0 |
0 |
|
|
|
5) Records of heat exchanger requirements |
|
10 |
$0 |
1 |
10 |
17 |
170 |
9 |
17 |
$18,492 |
$0 |
0 |
|
|
E. Personnel Training |
|
|
Incl. in 3.B |
|
|
|
|
|
|
|
|
|
|
|
|
F. Time for Audits |
|
|
N/A |
|
|
|
|
|
|
|
|
|
|
|
Recordkeeping Subtotal |
|
|
|
|
|
|
|
|
1190 |
59.5 |
119 |
$129,441 |
$0 |
0 |
|
TOTAL: |
|
|
|
|
|
|
|
|
2,803 |
140 |
280 |
$304,893 |
$2,469,800 |
34 |
|
|
|
|
|
|
|
|
|
|
|
Total Hours |
Labor |
Non-Labor |
Total |
|
|
|
|
|
|
|
|
|
Summary of Respondent Burden |
|
|
3,223 |
$304,893 |
$2,469,800 |
$2,774,693 |
|
|
|
|
|
|
|
|
|
Initial Capital and Startup |
|
|
|
|
$0 |
|
|
|
|
|
|
|
|
|
|
Annualized Capital/Start-up and O & M |
|
$2,469,800 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
FOOTNOTES |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
a |
One-time only costs. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
b |
Cost incurred by a facility regardless of the number of affected units at the plant. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
c |
Annual cost. Annual costs are not incurred until the second year of operation. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
d |
Based on the sum of the total capital costs for each monitoring system required for PVC facilities. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
e |
Based on the sum of the annualized capital costs for each monitoring system required for PVC facilities. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
f |
Hours for affirmative defense are shown only for illustration and are not included in the total burden estimate |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Attachment 3 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Table 5 - Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting Requirements of the MACT Floor for Existing Sources: Polyvinyl Chloride and Copolymer Manufacturing Units - Year 1 |
|
|
|
|
|
(A) |
(B) |
(C) |
(D) |
(E) |
(F) |
Burden Item |
Number of Occurrences Per Year |
EPA Hours Per Occurrence |
Tech Hours Per Year (C=AxB) |
Management Hours Per Year (D=Cx0.05) |
Clerical Hours Per Year (E=Cx0.1) |
EPA Cost Per Year (a,b) |
1. |
Applications |
|
|
|
not applicable |
2. |
Read and Understand Rule Requirements |
|
|
|
10 |
|
16 |
160 |
8 |
16 |
$8,292 |
3. |
Required Activities |
|
|
|
|
|
|
|
|
|
|
|
A. |
Observe initial performance tests |
3 |
b |
48 |
163 |
8 |
16 |
$8,457 |
|
B. |
Excess emissions -- Enforcement Activities |
|
|
2 |
d |
24 |
41 |
2 |
4 |
$2,114 |
|
C. |
Create Information |
|
|
not applicable |
|
D. |
Gather Information |
|
|
not applicable |
|
E. |
Report Reviews |
|
|
|
|
|
|
|
|
|
|
|
1) |
Review initial notification |
|
17 |
|
3 |
51 |
3 |
5 |
$2,643 |
|
|
2) |
Review batch precompliance report |
|
17 |
|
5 |
85 |
4 |
9 |
$4,405 |
|
|
3) |
Review notification of performance test |
|
17 |
|
10 |
170 |
9 |
17 |
$8,810 |
|
|
4) |
Review notification of compliance status |
|
17 |
|
40 |
680 |
34 |
68 |
$35,239 |
|
|
5) |
Review compliance report |
|
0 |
|
20 |
0 |
0 |
0 |
$0 |
|
|
6) |
Review notice of inspection |
|
17 |
|
3 |
51 |
3 |
5 |
$2,643 |
|
|
7) |
Review affirmative defense |
|
0 |
|
10 |
0 |
0 |
0 |
$0 |
|
F. |
Prepare annual summary report |
|
|
1 |
c |
200 |
200 |
10 |
20 |
$10,364 |
4. |
Travel expenses: (1 person * 30 hours per year / 8 hours per day * $75 per diem) + ($600 per round trip) = |
|
|
|
|
|
|
|
$881 |
per trip |
$2,996 |
|
TOTAL |
|
|
|
|
|
|
1601 |
80 |
160 |
$85,964 |
|
|
|
|
|
|
|
|
|
|
|
|
FOOTNOTES |
|
|
|
|
|
|
|
|
|
|
|
a |
Figures may not add exactly due to rounding. |
|
|
|
|
|
|
|
|
|
|
b |
Assumes EPA personnel attend 20 percent of the initial stack tests. |
|
|
|
|
|
|
|
|
|
|
c |
Using four hours per state to write annual summary report. |
|
|
|
|
|
|
|
|
|
|
d |
Assume 10% have emission exceedances. |
|
|
|
|
|
|
|
|
|
|
|
|
|
Attachment 3 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Table 6 - Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting Requirements of the MACT Floor for Existing Sources: Polyvinyl Chloride and Copolymer Manufacturing Units - Year 2 |
|
|
|
|
|
(A) |
(B) |
(C) |
(D) |
(E) |
(F) |
Burden Item |
Number of Occurrences Per Year |
EPA Hours Per Occurrence |
Tech Hours Per Year (C=AxB) |
Management Hours Per Year (D=Cx0.05) |
Clerical Hours Per Year (E=Cx0.1) |
EPA Cost Per Year (a,b) |
1. |
Applications |
|
|
|
not applicable |
2. |
Read and Understand Rule Requirements |
|
|
|
0 |
|
16 |
0 |
0 |
0 |
$0 |
3. |
Required Activities |
|
|
|
|
|
|
|
|
|
|
|
A. |
Observe initial performance tests |
0 |
b |
48 |
0 |
0 |
0 |
$0 |
|
B. |
Excess emissions -- Enforcement Activities |
|
|
2 |
d |
24 |
41 |
2 |
4 |
$2,114 |
|
C. |
Create Information |
|
|
not applicable |
|
D. |
Gather Information |
|
|
not applicable |
|
E. |
Report Reviews |
|
|
|
|
|
|
|
|
|
|
|
1) |
Review initial notification |
|
0 |
|
3 |
0 |
0 |
0 |
$0 |
|
|
2) |
Review batch precompliance report |
|
0 |
|
5 |
0 |
0 |
0 |
$0 |
|
|
3) |
Review notification of performance test |
|
0 |
|
10 |
0 |
0 |
0 |
$0 |
|
|
4) |
Review notification of compliance status |
|
0 |
|
40 |
0 |
0 |
0 |
$0 |
|
|
5) |
Review compliance report |
|
17 |
|
20 |
340 |
17 |
34 |
$17,620 |
|
|
6) |
Review notice of inspection |
|
17 |
|
3 |
51 |
3 |
5 |
$2,643 |
|
|
7) |
Review affirmative defense |
|
0 |
|
10 |
0 |
0 |
0 |
$0 |
|
F. |
Prepare annual summary report |
|
|
1 |
c |
200 |
200 |
10 |
20 |
$10,364 |
4. |
Travel expenses: (1 person * 30 hours per year / 8 hours per day * $75 per diem) + ($600 per round trip) = |
|
|
|
|
|
|
|
n/a |
per trip |
$0 |
|
TOTAL |
|
|
|
|
|
|
632 |
32 |
63 |
$32,741 |
|
|
|
|
|
|
|
|
|
|
|
|
FOOTNOTES |
|
|
|
|
|
|
|
|
|
|
|
a |
Figures may not add exactly due to rounding. |
|
|
|
|
|
|
|
|
|
|
b |
Assumes EPA personnel attend 20 percent of the initial stack tests. |
|
|
|
|
|
|
|
|
|
|
c |
Using four hours per state to write annual summary report. |
|
|
|
|
|
|
|
|
|
|
d |
Assume 10% have emission exceedances. |
|
|
|
|
|
|
|
|
|
|
|
|
|
Attachment 3 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Table 7 - Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting Requirements of the MACT Floor for Existing Sources: Polyvinyl Chloride and Copolymer Manufacturing Units - Year 3 |
|
|
|
|
|
(A) |
(B) |
(C) |
(D) |
(E) |
(F) |
Burden Item |
Number of Occurrences Per Year |
EPA Hours Per Occurrence |
Tech Hours Per Year (C=AxB) |
Management Hours Per Year (D=Cx0.05) |
Clerical Hours Per Year (E=Cx0.1) |
EPA Cost Per Year (a,b) |
1. |
Applications |
|
|
|
not applicable |
2. |
Read and Understand Rule Requirements |
|
|
|
0 |
|
16 |
0 |
0 |
0 |
$0 |
3. |
Required Activities |
|
|
|
|
|
|
|
|
|
|
|
A. |
Observe initial performance tests |
0 |
b |
48 |
0 |
0 |
0 |
$0 |
|
B. |
Excess emissions -- Enforcement Activities |
|
|
2 |
d |
24 |
41 |
2 |
4 |
$2,114 |
|
C. |
Create Information |
|
|
not applicable |
|
D. |
Gather Information |
|
|
not applicable |
|
E. |
Report Reviews |
|
|
|
|
|
|
|
|
|
|
|
1) |
Review initial notification |
|
0 |
|
3 |
0 |
0 |
0 |
$0 |
|
|
2) |
Review batch precompliance report |
|
|
|
5 |
|
|
|
|
|
|
3) |
Review notification of performance test |
|
0 |
|
10 |
0 |
0 |
0 |
$0 |
|
|
4) |
Review notification of compliance status |
|
0 |
|
40 |
0 |
0 |
0 |
$0 |
|
|
5) |
Review compliance report |
|
17 |
|
20 |
340 |
17 |
34 |
$17,620 |
|
|
6) |
Review notice of inspection |
|
17 |
|
3 |
51 |
3 |
5 |
$2,643 |
|
|
7) |
Review affirmative defense |
|
0 |
|
10 |
0 |
0 |
0 |
$0 |
|
F. |
Prepare annual summary report |
|
|
1 |
c |
200 |
200 |
10 |
20 |
$10,364 |
4. |
Travel expenses: (1 person * 30 hours per year / 8 hours per day * $75 per diem) + ($600 per round trip) = |
|
|
|
|
|
|
|
n/a |
per trip |
$0 |
|
TOTAL |
|
|
|
|
|
|
632 |
32 |
63 |
$32,741 |
|
|
|
|
|
|
|
|
|
|
|
|
FOOTNOTES |
|
|
|
|
|
|
|
|
|
|
|
a |
Figures may not add exactly due to rounding. |
|
|
|
|
|
|
|
|
|
|
b |
Assumes EPA personnel attend 20 percent of the initial stack tests. |
|
|
|
|
|
|
|
|
|
|
c |
Using four hours per state to write annual summary report. |
|
|
|
|
|
|
|
|
|
|
d |
Assume 10% have emission exceedances. |
|
|
|
|
|
|
|
|
|
|