Calculation Tables for ICR No.1666.10

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Overview

No of Respondents
No of Responses
Capital O&M
IndustryBurden
AgencyBurden

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Sheet 1: No of Respondents

Number of Respondents
	(A)	(B)	(C)	(D)	(E)
Year	Number of New Respondents 1	Number of Existing Respondents	Number of Existing Respondents that keep records but do not submit reports	Number of Existing Respondents That Are Also New Respondents	Number of Respondents
					(E=A+B+C-D)
1	2	111	12	1	124
2	2	112	12	1	125
3	2	113	12	1	126
Average	2	112	12	1	125

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Sheet 2: No of Responses

Total Annual Responses
(A)	(B)	(C)	(D)	(E)
Information Collection Activity	Number of Respondents	Number of Responses	Number of Existing Respondents That Keep Records But Do Not Submit Reports	Total Annual Responses
				E=(BxC)+D
Notification of Applicability	2	1	0	2
Notification of Construction/Reconstruction	2	1	0	2
Notification of Actual Startup	2	1	0	2
Notification of Initial Performance Test	2	1	0	2
Notification of Compliance Status	2	1	0	2
Request for Waiver	0.2	1	0	0.2
Report for Alternative Method/ Monitoring	0.1	1	0	0.1
Report for Performance Test	2	1	0	2
Reports for Periods of Noncompliance	112	2	12	236
			Total	248.3

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Sheet 3: Capital O&M

Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A)	(B)	(C)	(D)	(E)	(F)	(G)
Continuous Monitoring Device	Capital/Startup Cost for One Respondent	Number of New Respondents	Total Capital/Startup Cost, (B X C)	Annual O&M Costs for One Respondent	Number of Respondents with O&M	Total O&M,
						(E X F)
Computer equipment and GC 1	$32,500	2	$65,000	$5,500	112	$616,000
1 Computer equipment and gas chromatograph (GC) are used to continuously monitor EO emissions to aeration room and back chamber vents							Total	$681,000

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Sheet 4: IndustryBurden

					106.45	138.43	52.77
Burden Items	(A) Hours per occurrence	(B) Occurrences per year	(C) Hours per year (AxB)	(D) Respondents per year a	(E) Technical hours per year (CxD)	(F) Managerial hours per year (Ex0.05)	(G) Clerical hours per year (Ex0.10)	(H) Total Cost per year, $ b
1. Applications	N/A
2. Survey and Studies	N/A
3. Reporting Requirements
A. Familiarization with the regulatory requirements	1	1	1	125	125	6.25	12.5	$14,831.06
B. Required Activities
Initial performance test c	200	1	200	2	400	20	40	$47,459.40
Repeat performance test c, d	200	1	200	0.4	80	4	8	$9,491.88
Preparation of site-specific test plan	Included Above
C. Create Information	See 3B
D. Gather Existing Information	See 3B
E. Write Reports
Notification of applicability e	2	1	2	2	4	0.2	0.4	$474.59
Notification of construction/reconstruction e	2	1	2	2	4	0.2	0.4	$474.59
Notification of actual startup e	2	1	2	2	4	0.2	0.4	$474.59
Notification of initial performance test e	2	1	2	2	4	0.2	0.4	$474.59
Notification of compliance status e	2	1	2	2	4	0.2	0.4	$474.59
Request for extension of compliance, adjustment to time periods, and changes in information	2	1	2	0	0	0	0	$0.00
Request for waiver f	6	1	6	0.2	1.2	0.06	0.12	$142.38
Report for alternative method monitoring m	6	1	6	0.1	0.6	0.03	0.06	$71.19
Report for performance test g	24	1	24	2	48	2.4	4.8	$5,695.13
Reports for periods of noncompliance (including excess emissions) h	14	2	28	112	3,136	156.8	313.6	$372,081.70
Subtotal for Reporting					4,382			$452,145.70
4. Recordkeeping Requirements
A. Familiarization with the regulatory requirements	See 3A
B. Plan Activities	See 3B
C. Implement Activities	See 3B
D. Develop Record System	See 3B
E. Time to Enter Information
Record of operating parameters and emissions i	0.1	365	36.5	112	4,088	204.4	408.8	$485,035.07
Records of EO use j, k	0.6	12	7.2	12	86.4	4.32	8.64	$10,251.23
F. Time to transmit or disclose information l	0.25	2	0.5	112	56	2.8	5.6	$6,644.32
G. Train Personnel	N/A
H. Time for Audits	N/A
Subtotal for Recordkeeping					4,865			$501,930.61
Total Labor Burden and Cost (rounded) n					9,200			$950,000		37	hr per resp
Capital and O&M Cost (see Section 6(b)(iii)): n								$681,000
TOTAL COST: n								$1,630,000
Assumptions:
a The average number of respondents that will be subject to the rule will be the 125 existing respondents. There will be two additional new sources per year that will become subject to the rule over the 3-year period of this ICR.
b This ICR uses the following labor rates: $138.43 for Managerial, $106.45 for Technical, and $52.77 for Clerical.
c It is assumed that it will take 200 hours for each respondent to perform the initial performance test and also repeat testing.
d It is assumed that 20 percent of respondents will have to repeat performance tests due to failure.
e It is assumed that it will initially take each of the new respondents two hours to write each notification report.
f It is assumed that 10 percent of new facilities will take 5 hours to write requests for waivers.
g It is assumed that each respondent will take 24 hours to prepare performance test reports.
h It is assumed that 112 respondents will take 14 hours to complete reports of periods of noncompliance, which includes excess emissions. This will occur two time per year.
i It is assumed that 112 respondents will enter information on record of operating parameters and emissions 365 times per year.
j It is assumed that the average number of affected facilities required to record EO usage is 12.
k It is assumed that each of the 12 respondents will record EO use 12 times per year.
l It is assumed that 112 respondents will disclose information two time per year.
m It is assumed that 5 percent of new facilities will request an alternative method monitoring.
n Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 5: AgencyBurden

					47.62	64.16	25.76
Activity	(A) EPA Hours per Occurrence	(B) Occurrences per Year	(C) EPA Hours per Year (AxB)	(D) Plants per Year a	(E) Technical Hours per Year (CxD)	(F) Managerial Hours per Year (Ex0.05)	(G) Clerical hours per year (Ex0.10)	(H) Total cost per year $ b
Initial performance tests
New or modified facility c	40	1	40	2	80	4	8	$4,272.32
Repeat performance tests
New or modified facility d	136	1	136	0.4	54.4	2.72	5.44	$2,905.18
Report Review
New or modified facility
Notification of applicability	2	1	2	2	4	0.2	0.4	$213.62
Notification of construction/reconstruction e	2	1	2	2	4	0.2	0.4	$213.62
Notification of actual startup e	2	1	2	2	4	0.2	0.4	$213.62
Notification of initial performance test e	2	1	2	2	4	0.2	0.4	$213.62
Notification of compliance status e	2	1	2	2	4	0.2	0.4	$213.62
Request for extension of compliance, adjustment to time periods, and changes in information	2	1	2	2	4	0.2	0.4	$213.62
Request for waiver g	4	1	4	0.2	0.8	0.04	0.08	$42.72
Request for alternative method/monitoring h	4	1	4	0.1	0.4	0.02	0.04	$21.36
Report of performance test i	8	1	8	2	16	0.8	1.6	$854.46
Report of periods of noncompliance (including excess emissions) j	8	2	16	22.4	358.4	17.92	35.84	$19,139.99
Total Labor Burden and Cost (rounded) k					614			$28,500
Assumptions:
a It is assumed that the average number of respondents that will be subject to the rule will be the 136 existing respondents. There will be two additional new sources 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: $64.16 for Managerial, $47.62 for technical, and $25.76 for Clerical.
c It is assumed that it will take 40 hours for each respondent to participate with performance test. Twenty percent of respondents will fail the performance test.
d It is assumed that 20 percent of respondent will fail the performance test and will have to repeat it.
e It is assumed that it will take two hours for each respondent to review the notification report.
f It is assumed that it will take two hours for each respondent to review the request for extension of the compliance report.
g It is assumed that 10 percent of new facilities will request a waiver.
h It is assumed that 5 percent of new facilities will request an alternative method monitoring.
i It is assumed that each new respondent will take 8 hours to review the report of performance test results.
j It is assumed that 20 percent of respondents submitting reports will take 8 hours to review reports of period of noncompliance.
k Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.