| Table 1: Annual Respondent Burden and Cost – NSPS for Synthetic Fiber Production Facilities (40 CFR Part 60, Subpart HHH) (Renewal) |
|
|
|
|
|
|
|
|
|
|
|
|
|
103.97 |
129.93 |
51.79 |
|
| Burden item |
(A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
(H) |
| Person-hours per occurrence |
No. of occurrences per respondent per year |
Person hours per respondent per year (AxB) |
Respondents per yeara |
Technical person-hours per year (CxD) |
Management person-hours per year (Ex0.05) |
Clerical person-hours per year (Ex0.1) |
Cost, $b |
| 1. Applications |
N/A |
|
|
|
|
|
|
|
| 2. Survey and Studies |
N/A |
|
|
|
|
|
|
|
| 3. Reporting Requirements |
|
|
|
|
|
|
|
|
| A. Familiarize with rule requirements |
1 |
1 |
1 |
22 |
22 |
1.1 |
2.2 |
$2,544 |
| B. Required activities |
|
|
|
|
|
|
|
|
| Initial performance test |
72 |
1 |
72 |
0 |
0 |
0 |
0 |
$0 |
| Repeat performance test c |
72 |
DWang:
Changed from 1
0.2 |
14.4 |
0 |
0 |
0 |
0 |
$0 |
| C. Create information |
See 3B |
|
|
|
|
|
|
|
| D. Gather existing information |
See 3B |
|
|
|
|
|
|
|
| E. Write report |
|
|
|
|
|
|
|
|
| New Sources |
|
|
|
|
|
|
|
|
| Notification of construction/ reconstruction d |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0.00 |
| Notification of actual startup d |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0.00 |
| Notification of initial performance test d |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0.00 |
| Notification of demonstration of CMS d |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0.00 |
| Report of initial performance test d |
See 3B |
|
|
|
|
|
|
|
| Existing Sources |
|
|
|
|
|
|
|
|
| Quarterly report of VOCs emission exceedances e |
8 |
0.5 |
4 |
22 |
88 |
4.4 |
8.8 |
$10,176.80 |
| Semiannual report of no exceedances f |
2 |
2 |
4 |
22 |
88 |
4.4 |
8.8 |
$10,176.80 |
|
DWang:
I don't think that it should be called a notification of non-compliance:
60.604(b): Solvent-spun synthetic fiber producing facilities exempted from these standards in §60.600(a) (those producing less than 500 Mg (551 ton) annually) shall report to the Administrator within 30 days whenever extruded fiber for the preceding 12 calendar months exceeds 500 Mg (551 ton).
Changing to "Notification of eligibility". Does that make sense?
Notification of limit exceedance for extruded fiber g |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0.00 |
| Subtotal for Reporting Requirements |
|
|
|
|
228 |
$22,898 |
| 4. Recordkeeping requirements |
|
|
|
|
|
|
|
|
| A. Familiarize with rule requirements |
See 3A |
|
|
|
|
|
|
|
| B. Plan activities |
See 4C |
|
|
|
|
|
|
|
| C. Implement activities |
See 3B |
|
|
|
|
|
|
|
| D. Develop record system |
See 4E |
|
|
|
|
|
|
|
| E. Time to enter information |
|
|
|
|
|
|
|
|
| Records of operating parameters h |
0.25 |
250 |
62.5 |
22 |
1375 |
68.75 |
137.5 |
$159,012.56 |
| Records of monthly VOC emission i |
0.25 |
12 |
3 |
22 |
66 |
3.3 |
6.6 |
$7,632.60 |
| F. Time to train personnel |
N/A |
|
|
|
|
|
|
|
| G. Time for audits |
N/A |
|
|
|
|
|
|
|
| Subtotal for Recordkeeping Requirements |
|
|
|
|
1,657 |
$166,645 |
| TOTAL LABOR BURDEN AND COST(roundedj) |
1,880 |
$190,000 |
| Total Capital/O&M Costs (rounded)j |
$165,000 |
| Grand Total (Labor and Capital/O&M Costs)(rounded)j |
$355,000 |
|
|
|
|
|
|
|
|
|
| Assumptions: |
|
|
|
|
|
|
|
|
| a We have assumed that the average number of respondents that will be subject to the rule will be 22. There will be no additional new source 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 We have assumed that 20 percent of initial performance tests will be repeated. |
| d We have assumed that there will be no new sources over the three-year period of this ICR. |
| e We have assumed that each respondent will submit one quarterly report every other year due to excess of volatile organic compounds (VOCs) emissions. |
| f Semiannual reports are required of all respondents. |
| g We have assumed that there are no existing solvent-spun synthetic fiber producing facility subject to the exemption under section 60.600(a) that would have exceeded the annual requirement of 500 mg. Therefore, no existing solvent-spun synthetic fiber producing facility will submit a notification of exceeding the limits over the three-year period of the ICR. |
| h We have assumed that respondents will enter information on records of operating parameters 250 days per year. |
| i Respondents are required to conduct monthly calculation of the 6 months VOC average emission which is considered a performance test. Respondents will have to determine this value by calculating the VOC emissions per unit of mass solvent feed from each affected facility for the current and proceeding five consecutive calendar months. |
| j Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
Table 2: Average Annual EPA Burden and Cost – NSPS for Synthetic Fiber Production Facilities (40 CFR Part 60, Subpart
HHH) (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 (AxB) |
Plants per yeara |
Technical person-hours per year (CxD) |
Management person-hours per year (Ex0.05) |
Clerical person-hours per year (Ex0.1) |
Cost, $b |
| Required Activities |
|
|
|
|
|
|
|
|
| New Plant |
|
|
|
|
|
|
|
|
| Initial performance test |
24 |
1 |
24 |
0 |
0 |
0 |
0 |
$0 |
| Repeat performance test c |
24 |
0.2 |
4.8 |
0 |
0 |
0 |
0 |
$0 |
| Report review |
|
|
|
|
|
|
|
|
| New Plant |
|
|
|
|
|
|
|
|
| Notification of construction |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
| Notification of actual startup |
0.5 |
1 |
0.5 |
0 |
0 |
0 |
0 |
$0 |
| Notification of initial test |
0.5 |
1.2 |
0.6 |
0 |
0 |
0 |
0 |
$0 |
| Review test results |
8 |
1.2 |
9.6 |
0 |
0 |
0 |
0 |
$0 |
| Notification of demonstration of CMS |
0.5 |
1 |
0.5 |
0 |
0 |
0 |
0 |
$0 |
| Existing Plant |
|
|
|
|
|
|
|
|
| Quarterly report of VOCs emission exceedances d |
2 |
0.5 |
1 |
22 |
22 |
1.1 |
2.2 |
$1,151 |
| Semiannual report of no VOC emission exceedances e |
2 |
2 |
4 |
22 |
88 |
4.4 |
8.8 |
$4,606 |
| Notification of limit exceedance for extruded fiber |
2 |
0 |
0 |
0 |
0 |
0 |
0 |
$0 |
| TOTAL ANNUAL BURDEN AND COST (rounded) f |
|
|
|
|
127 |
$5,760 |
|
|
|
|
|
|
|
|
|
| Assumptions: |
|
|
|
|
|
|
|
|
| a We have assumed that the average number of respondents that will be subject to the rule will be 22. There will be no additional new source that will become subject to the rule over the three-year period of this ICR. |
| b This cost is based on the following hourly labor rates: $62.90 for Managerial (GS-13, Step 5, $39.31 + 60%), $46.67 for Technical (GS-12, Step 1, $29.17 + 60%) and $25.25 Clerical (GS-6, Step 3, $15.78 + 60%). These rates are from the Office of Personnel Management (OPM) "2014 General Schedule" which excludes locality rates of pay. The rates have been increased by 60% to account for the benefit packages available to government employees. |
| c We have assumed that 20 percent of initial performance tests will be repeated. |
| d We have assumed that each respondent will submit one quarterly report every other year due to excess of volatile organic compounds (VOCs) emissions. |
| e Semiannual reports are required of all respondents. |
| f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |