Annual Respondent Burden and Cost – NESHAP for Printing, Coating and Dyeing of Fabrics and Other Textiles (Renewal)

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Overview

Industry
Agency

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Sheet 1: Industry

Table 1: Annual Respondent Burden and Cost – NESHAP for Printing, Coating and Dyeing of Fabrics and Other Textiles (40 CFR Part 63, Subpart OOOO) (Renewal)
					103.97	129.93	51.79
Burden item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Person - hours per occurrence	No. of occurrence per respondent per year	Person-hours per respondent per year	Respondents per year a	Technical Person - hours per year	Management person-hours per year	Clerical person - hours per year	Cost, $ b
			(C=AxB)		(E=CxD)	(Ex0.05)	(Ex0.1)				72	coating and printing facilities
1. Applications	N/A										74	slashing, dyeing, and finishing facilities
2. Survey and Studies	N/A										146	Total
3. Reporting Requirements
A. Familiarization with rule requirement	4	1	4	146	584	29.2	58.4	$67,536.97
B. Required activities
Initial oxidizer performance test c, e	280	1	280	1	280	14	28	$32,380.74
Repeat oxidizer performance test c, e, f	280	1	280	0.2	56	2.8	5.6	$6,476.15
Initial capture performance test c, e	215	1	215	1	215	10.75	21.5	$24,863.78
Repeat capture performance test c, e, f	215	1	215	0.2	43	2.15	4.3	$4,972.76
Startup, shutdown, malfunction plan c	40	1	40	1	40	2	4	$4,625.82
Solvent recovery system compliance determination c, p	4	12	48	14.4	691.2	34.56	69.12	$79,934.17
Emission rate limit compliance determination	4	12	48	146	7,008	350.4	700.8	$810,443.66
Coordination with suppliers g	40	1	40	146	5,840	292	584	$675,369.72
C. Create information	See 4B
D. Gather existing information	See 4B
E. Write report
Initial notification c	2	1	2	1	2	0.1	0.2	$231.29
Notification of construction/reconstruction c	2	1	2	1	2	0.1	0.2	$231.29
Notification of anticipated startup c	2	1	2	1	2	0.1	0.2	$231.29
Notification of actual startup c	2	1	2	1	2	0.1	0.2	$231.29
Notification of compliance status c	4	1	4	1	4	0.2	0.4	$462.58
Notification of performance test c, e	2	1	2	1	2	0.1	0.2	$231.29
Performance test report c, e	40	1	40	1	40	2	4	$4,625.82
Report of monitoring exceedances c, h, k	16	2	32	7.2	230.4	11.52	23.04	$26,644.72
Report of no excess emissions c, i, k	8	2	16	64.8	1,037	51.84	103.68	$119,901.25
Startup, shutdown, malfunction report c, j, k	8	2	16	7.2	115.2	5.76	11.52	$13,322.36
Report of compliance deviation d, k, l	16	2	32	7.4	236.8	11.84	23.68	$27,384.85
Report of no compliance deviations d, k, m	8	2	16	66.6	1,066	53.28	106.56	$123,231.84
Subtotal for Reporting Requirements					20,120			$2,023,333.67
4. Recordkeeping Requirements
A. Familiarization with rule requirement	See 4B
B. Plan activities	N/A
C. Implement activities	N/A
D. Develop record system	N/A
E. Time to enter information
Records of all information required by standards n	0.25	52	13	146	1,898	94.9	189.8	$219,495.16
F. Time to train personnel	N/A
G. Time to adjust existing ways to comply with previously applicable requirements	N/A
H. Time to transmit or disclose information o	0.25	2	0.5	146	73	3.65	7.3	$8,442.12
I. Time for audits	N/A
Subtotal for Recordkeeping Requirements					2,267			$227,937.28
TOTAL LABOR BURDEN AND COST q					22,400			$2,250,000		72	hr/resp
Capital and O&M Cost (see Section 6(b)(iii)): q								$6,750
TOTAL COST: q								$2,260,000
Assumptions:
a We have assumed that the average number of respondents that will be subject to the rule will be 146, which equates to 69 coating and printing sources, and 74 slashing, dyeing, and finishing sources. There will be one additional new source per year that will become subject to the rule over the three-year period of this ICR.
b This ICR uses the following labor rates: $129.93 per hour for Executive, Administrative, and Managerial labor; $103.97 per hour for Technical labor, and $51.79 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2014, “Table 2: Civilian Workers, 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.
c This applies only to coating and printing facilities.
d This applies only to slashing, dyeing and finishing facilities.
e Occurs one time for new sources and involves one-time startup costs associated with initial compliance determination and acquisition, installation, and utilization of technology and systems needed to support recordkeeping and reporting.
f It is assumed that 20 percent of respondents will have to repeat performance tests.
g We have assumed that it will take 40 hours for each respondent to coordinate with suppliers.
h We have assumed that 10 percent of respondents will report monitoring exceedances.
i We have assumed that 90 percent of respondents will report no excess emissions.
j We have assumed that 10 percent of respondents will file a startup, shutdown, malfunction reports.
k Semiannual reports are required.
l It is assumed that 10 percent of respondents will report compliance deviations.
m It is assumed that 90 percent of respondents will report no compliance deviations.
n It is assumed that all of the respondents will be required to record information on a weekly basis.
o It is assumed that respondents will be required to transmit/disclose information on a semiannual basis.
p It is assumed that 20 percent of the coating and printing facilities will use solvent recovery equipment.
q Totals have been rounded to 3 significant values. Figures may not add exactly due to rounding.

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Sheet 2: Agency

Table 2: Average Annual EPA Burden and Cost – NESHAP for Printing, Coating and Dyeing of Fabrics and Other Textiles (40 CFR Part 63, Subpart OOOO) (Renewal)
					46.67	62.9	25.25
Activity	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	EPA person- hours per occurrence	No. of occurrences per plant per year	EPA person hours per plant per year	Plants per year a	Technical person-hours per year	Management person-hours per year	Clerical person- hours per year	Cost, $ b
			(C=AxB)		(E=CxD)	(Ex0.05)	(Ex0.1)				72	coating and printing facilities
1. Initial performance test c	495	1	495	1	495	24.75	49.5	$25,908.30			74	slashing, dyeing, and finishing facilities
2. Repeat performance test preparations c, e	4	0.1	0.4	1	0.4	0.02	0.04	$20.94			146	Total
3. Repeat performance test c, e	495	0.1	49.5	1	49.5	2.475	4.95	$2,590.83
4. Report Review
Notification of applicability	2	1	2	1	2	0.1	0.2	$104.68
Notification of construction/ reconstruction	2	1	2	1	2	0.1	0.2	$104.68
Notification of anticipated startup	2	1	2	1	2	0.1	0.2	$104.68
Notification of actual startup	2	1	2	1	2	0.1	0.2	$104.68
Notification of initial performance test c	2	1	2	1	2	0.1	0.2	$104.68
Notification of compliance status c	2	1	2	1	2	0.1	0.2	$104.68
Review of initial performance test report c	8	1	8	1	8	0.4	0.8	$418.72
Review of repeat performance test report c, f	8	0.1	0.8	1	0.8	0.04	0.08	$41.87
Review of excess emissions report c, g	8	1	8	7.2	57.6	2.88	5.76	$3,014.78
Review of no excess emissions report c, h	2	1	2	64.8	129.6	6.48	12.96	$6,783.26
Review of startup, shutdown, malfunction reports c, i	2	1	2	7.2	14.4	0.72	1.44	$753.70
Review of compliance deviations report d, j	8	1	8	7.4	59.2	2.96	5.92	$3,098.53
Review of no compliance deviations reports d, k	2	1	2	66.6	133.2	6.66	13.32	$6,971.69
TOTAL ANNUAL BURDEN AND COST l					1,100			$50,200
Assumptions:
a We have assumed that the average number of respondents that will be subject to the rule will be 145, which equates to 70 coating and printing sources, and 75
slashing, dyeing, and finishing sources. There will be one additional new source per year that will become subject to the rule over the three-year period of this ICR.
b This cost is based on the following labor rates which incorporate a 1.6 benefits multiplication factor to account for government overhead expenses: Managerial rate of $62.90 (GS-13, Step 5, $39.31 x 1.6), Technical rate of $46.67 (GS-12, Step 1, $29.17 x 1.6), and Clerical rate of $25.25 (GS-6, Step 3, $15.78 x 1.6). These rates are from the Office of Personnel Management (OPM) “2015 General Schedule” which excludes locality rates of pay.
c This applies only to coating and printing facilities.
d This applies only to slashing, dyeing and finishing facilities.
e We have assumed that 10 percent of new sources will have to repeat performance test preparations and testing.
f Assume that 10 percent of new sources will review the repeat performance test report.
g We have assumed that 10 percent of respondents will be engaged in the reviewing of excess emissions reports.
h We have assumed that 90 percent of respondents will be engaged in the reviewing of no excess emissions reports.
i We have assumed that 10 percent of respondents will have to review the startup, shutdown, malfunction reports.						*updated this to 10% from 20% to match the rest of the report
j We have assumed that 10 percent of respondents will review the compliance deviations report.
k We have assumed that 90 percent of respondents will review the no compliance deviations report.
l Totals have been rounded to 3 significant values. Figures may not add exactly due to rounding.