Burden calculations

1080.15 Calculations_final.xlsx

NESHAP for Benzene Emission from Benzene Storage Vessels and Coke Oven By-Product Recovery Plants (40 CFR Part 61, Subparts L and Y) (Renewal)

Burden calculations

OMB: 2060-0185

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Overview

# Respondents & Responses Calcs
Respondent Burden (Subs L & Y)
Agency Burden (Subs L & Y)


Sheet 1: # Respondents & Responses Calcs

Number of Respondents






Respondents That Submit Reports Respondents That Do Not Submit Any Reports
Total Annual Responses
Year (A)
Number of New Respondents1
(B)
Number of Existing Respondents2
(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)

(A)
Information Collection Activity
(B)
Average 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
Subpart L
Subpart L
1 0 17 0 0 17
Semiannual emissions report 17 2 0 34
2 0 17 0 0 17
Subtotal for subpart L


34
3 0 17 0 0 17
Subpart Y
Average 0 17 0 0 17
Annual inspection report 4 1 0 4
Subpart Y
Supplemental delay report 0.08 1 0 0.08
1 0 4 0 0 4
Subtotal for subpart Y (rounded)


4
2 0 4 0 0 4



Total 38
3 0 4 0 0 4





Average 0 4 0 0 4






Sheet 2: Respondent Burden (Subs L & Y)

Table 1: Annual Respondent Burden and Cost – NESHAP for Benzene Emission from Benzene Storage Vessels and Coke By-Product Recovery Plants (40 CFR Part 61, Subparts L and Y) (Renewal)






























Burden Item A B C D E F G H
TECH $106.45



Technical person-hours
per occurrence
No. of occurrences per respondent
per year
Technical person-hours per respondent
per year
(AxB)
Respondents per year a Technical hours per year (CxD) Management hours per year
(Ex0.05)
Clerical hours per year
(Ex0.10)
Total cost per year b
MGMT $138.43



Subpart L
CLER $52.77



1. Applications N/A













2. Survey and Studies N/A







New sources 0



3. Reporting requirements








Existing sources 17



A. Familiarize with regulation requirements 1 1 1.0 17 17.0 0.85 1.70 $2,017.02






B. Required activities














Initial performance test 32 1 32 0 0 0 0 $0






Repeat performance test 32 0.2 6.4 0 0 0 0 $0






Annual maintenance inspection c 0.5 1 0.5 17 8.5 0.43 0.85 $1,009.20






C. Create information See 3B













D. Gather existing information See 3E













E. Write Report














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






Notification of anticipated/actual startup 2 1 2 0 0 0 0 $0






Notification of initial performance test 2 1 2 0 0 0 0 $0






Notification of physical/operational chances 8 1 8 0 0 0 0 $0






Semiannual emissions report d 12 2 24 17 408 20.4 40.8 $48,408.59






Subtotal for Reporting Requirements



499 $51,434.82






4. Recordkeeping requirements














A. Familiarize with regulation requirements See 3A













B. Plan activities














Maintenance plan See 3A













C. Implement activities See 3B













File and maintain records e 33 4 132 17 2,244 112.2 224.4 $266,247.23






Performance evaluation for Method 21 f 2 2 4 17 68 3.4 6.8 $8,068.10






D. Develop record system N/A













E. Time to enter information N/A













F. Time to train personnel N/A













G. Time for audits N/A













Subtotal for Recodkeeping Requirements



2,659 $274,315.33






ANNUAL BURDEN AND COST (SUBPART L) (ROUNDED)



3,160 $326,000






Subpart Y






1. Applications N/A







New sources 0



2. Survey and Studies N/A







Existing sources 4



3. Reporting requirements














A. Familiarize with regulation requirements 1 1 1.0 4 4.0 0.20 0.40 $474.59






B. Required activities N/A













C. Create information














Existing sources














Annual IFR internal inspections and EFR seal gap measurementsg 8 1 8 4 32 1.6 3.2 $3,796.75






D. Gather existing information See 3C













E. Write Report














New sources














Notification of construction/reconstruction See NSPS Kb













Notification of anticipated/actual startup See NSPS Kb













Notification of performance test N/A













Report of performance test N/A













Notification of control installation and refill at 1st IFR degassing g,h 2 1 2 0 0 0 0 $0






Existing sources














Annual inspection reports 2 1 2 4 8 0.4 0.8 $949.19






Supplemental delay report i 2 1 2 0.08 0.16 0.01 0.02 $19.47






Quarterly emissions report j N/A













Subtotal for Reporting Requirements



51 $5,240.00






4. Recordkeeping requirements














A. Familiarize with regulation requirements See 3A













B. Plan activities See 4C













C. Implement activities














File and maintain records 2 1 2 4 8 0.4 0.8 $949.19






D. Develop record system See 4C













E. Time to enter information See 4C













F. Time to train personnel N/A













G. Time for audits N/A













Subtotal for Recodkeeping Requirements



9 $949.19






ANNUAL BURDEN AND COST (SUBPART Y) (ROUNDED)



60 $6,190






TOTAL ANNUAL BURDEN AND COST (SUBPARTS L and Y) (ROUNDED)



3,220 $332,000






Capital and O&M Costs (see Section 6(b)(iii))






$0






TOTAL (ROUNDED)k



3,220 $332,000














85 hrs/response





















































Assumptions:














a. We have assumed that an average of 17 respondents per year will be subject to 40 subpart L and an average of 4 respondents per year will be subject to subpart Y. No new sources will become subject to the rule over the three-year ICR period. Note that the burden for any new sources subject to subpart Y is included in the NSPS for storage vessels at 40 CFR part 60, subpart Kb.






b. This ICR uses the following labor rates: $106.45 for technical, $138.43 for managerial, and $52.77 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2015, “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 each respondent will take 0.5 hours to complete the annual maintenance inspection.














d. We have assumed that each respondent will take twelve hours twice per year to write semiannual emissions reports.














e. We have assumed that each respondent will take thirty-three hours four times per year to file and maintain records.









Summary of Responded Burden and Costs (Rounded)
f. We have assumed that each respondent will take two hours twice per year to complete the performance evaluation for Method 21.









Standard Reporting (hr) Recordkeeping (hr) Total Burden Hours (hr) Total Burden Costs
g. EFR - External Floating Roof. IFR - Internal Floating Roof.









Subpart L 479 2,659 3,140 $326,000
h. We believe that all vessels have been degassed and that all controls have been installed, as they were to be installed within ten years of promulgation.









Subpart Y 46 9 55 $6,190
i. We have assumed that two percent of existing sources will request a delay of repair in the annual report.









Total

3,200 $332,000
j. We have assumed that no sources will select the option for a fixed roof vented to a control device, and thus have no quarterly reports of excess emissions.














k. Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.















Sheet 3: Agency Burden (Subs L & Y)


Table 2: Average Annual EPA Burden and Cost – NESHAP for Benzene Emission from Benzene Storage Vessels and Coke By-Product Recovery Plants (40 CFR Part 61, Subparts L and Y) (Renewal)






































Burden Item A B C D E F G H
TECH $47.62







Technical person-hours per occurrence No. of occurrences per respondent per year Technical person-hours per respondent
per year
(AxB)
Respondents per year a Technical hours per year
(CxD)
Management hours per year (Ex0.05) Clerical hours per year
(Ex0.10)
Total cost per year b
MGMT $64.16







Subpart L
CLER $25.76







Initial performance test


















New plant 40 1 40 0 0 0 0 $0










Report review


















Notification of construction 2 1 2 0 0 0 0 $0










Notification of anticipated startup 2 1 2 0 0 0 0 $0










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










Notification of performance test 2 1 2 0 0 0 0 $0










Report of performance test 8 1 8 0 0 0 0 $0









1 Review semiannual excess emissions and exemption reports c 4 2 8 17 136 6.8 13.6 $7,262.94









2 ANNUAL BURDEN AND COST (SUBPART L, ROUNDED)



156 $7,260










Subpart Y










Report review


















New sources


















Notification of construction/reconstruction See NSPS Kb

















Notification of anticipated/actual startup See NSPS Kb

















Notification of performance test N/A

















Report of performance test N/A

















Notification of control installation and refill at 1st IFR degassing d,e 2 1 2 0 0 0 0 $0










Existing sources


















Annual inspection report 2 1 2 4 8 0.4 0.8 $427.23










Supplemental delay report f 2 1 2 0.08 0.16 0.01 0.02 $8.78










Quarterly emissions report g N/A

















ANNUAL BURDEN AND COST (SUBPART Y) (ROUNDED)



9 $436










TOTAL (ROUNDED)h



165 $7,700






































































Assumptions:


















a. We have assumed that an average of 17 respondents per year will be subject to 40 subpart L and an average of 4 respondents per year will be subject to subpart Y. No new sources will become subject to the rule over the three-year ICR period. Note that the burden for any new sources subject to subpart Y is included in the NSPS for storage vessels at 40 CFR part 60, subpart Kb.










b. This ICR uses the following labor rates: $47.62 for technical, $64.16 for managerial, and $25.76 for clerical labor. These rates are from the Office of Personnel Management (OPM), 2016 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.








c. We have assumed it will take the Agency four hours per respondent to review excess emissions and exception reports twice per year.














Summary of Agency Burden and Costs (Rounded)

d. IFR - Internal Floating Roof














Standard Total Burden Hours (hr) Total Burden Costs ($)

e. We believe that all vessels have been degassed and that all controls have been installed, as they were to be installed within ten years of promulgation.














Subpart L 0 $0

f. We have assumed that two percent of existing sources will request a delay of repair in the annual report.














Subpart Y 165 $7,700

g. We have assumed that no sources will select the option for a fixed roof vented to a control device, and thus have no quarterly reports of excess emissions.














Total 165 $7,700

h. Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

























































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