Burden Tables

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Overview

Industry
Agency

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Sheet 1: Industry

					Sep 2016 Labor Rates
					108.28	144.33	53.34
Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (A x B)	(D) Respondents per yeara	(E) Technical person- hours per year (C x D)	(F) Management person hours per year (E x0.05)	(G) Clerical person hours per year (E x 0.1)	(H) Total Cost per yearb
1. Applications	N/A
2. Surveys and studies	N/A
3. Reporting requirements
A. Familiarization with the regulatory requirementsa	1	1	1	7	7	0.4	0.7	$846
B. Required activitiesc
Basic liquid resins (BLR)	1,050	1	1050	0	0	0	0	$0
Repeat initial performance test - process vents	1,050	1	1050	0	0	0	0	$0
Initial performance test - wastewater	270	1	270	0	0	0	0	$0
Repeat initial performance test – wastewater	270	1	270	0	0	0	0	$0
Wet strength resins (WSR)d	270	1	270	0	0	0	0	$0
C. Create information	See 3B, 4D, 4E									# of Responses	54
D. Gather existing information	See 3B, 4D, 4E
E. Write report
Notification of construction/reconstruction c	2	1	2	0	0	0	0	$0
Notification of physical/operational changes e	2	1	2	1	2	0.1	0.2	$241.66		1
Notification of anticipated startup c	2	1	2	0	0	0	0	$0
Notification of actual startup c	2	1	2	0	0	0	0	$0
Notification of applicability of the standard – existing sourcesc	2	1	2	0	0	0	0	$0
Notification of applicability of the standard – new sourcesc	2	1	2	0	0	0	0	$0
Notification of initial performance test c	2	1	2	0	0	0	0	$0
Report of initial test (including CMS performance evaluation and results) c	6	1	6	0	0	0	0	$0
Submit quality control plan for CMS c, f	2	1	2	0	0	0	0	$0
Jennifer ONeil: I added footnote q here, it was listed in the footnotes before but I didn’t see where it was referred to ARS --Removed footnote q here as the note was for SSM report, not SSM plan. This is footnote c as it is a one-time requirement. Submit startup, shutdown, malfunction planc	2	1	2	0	0	0	0	$0
Report of monitoring exceedances and periods of noncomplianceg	16	4	64	1	64	3.2	6.4	$7,733.15		4
Report of no excess emissions h	8	4	32	6	192	9.6	19.2	$23,199.46		24
Report of area source becoming major i	6	1	6	0	0	0	0	$0
Waiver application j	6	1	6	1	6	0.3	0.6	$724.98		1
Compliance status information report c	4	1	4	0	0	0	0	$0
Submit semiannual SSM reports q	2	2	4	7	28	1.4	2.8	$3,383.25		14
Submit immediate reports of inconsistent procedures monitored at each affected source h	2	1	2	7	14	0.7	1.4	$1,691.63		7
Submit a CMS summary report for HAP monitored at each affected source k	2	1	2	3	6	0.3	0.6	$724.98		3
Subtotal for Reporting Requirements					367			$38,545
4. Recordkeeping requirements
A. Familiarization with the regulatory requirementsa	See 3A
B. Plan activities	N/A
C. Implement activities	See 4D, 4E
D. Develop record system c	40	1	40	0	0	0	0	$0
E. Time to enter information
a. Records of control device monitoring parameters:
- Continuously monitored parameters k, l	12	52	624	3	1872	93.6	187.2	$226,194.70
- LDAR program reporting and recordkeeping – BLR k	311	1	311	3	933	46.65	93.3	$112,734.86
- LDAR program reporting and recordkeeping – WSR m	11	1	11	4	44	2.2	4.4	$5,316.54
- Wastewater parameters k, n	2	12	24	3	72	3.6	7.2	$8,699.80
F. Other recordkeeping activities
a. Maintain records of occurrence and duration of each SSM of process and control equipment h, o	2	8	16	7	112	5.6	11.2	$13,533.02
b. Maintain records of maintenance performed on air pollution control equipment h	2	4	8	7	56	2.8	5.6	$6,766.51
c. Maintain records of all action taken during periods of SSM that differ from the sources SSM plan h, p	2	1	2	7	14	0.7	1.4	$1,691.63
d. Maintain records of each period during which a CMS is malfunctioning or inoperative k	2	1	2	3	6	0.3	0.6	$724.98
e. Maintain records of result of all performance test and performance evaluations c	2	1	2	0	0	0	0	$0
f. Maintain all initial notification and compliance status notifications c	1	1	1	0	0	0	0	$0
G. Time for audits	N/A
Subtotal for Recordkeeping Requirements					3,575			$376,000
TOTAL LABOR BURDEN AND COST (rounded)r					3,940			$415,000
TOTAL CAPITAL AND O&M COST (rounded)r								$9,000
GRAND TOTAL (rounded)r								$424,000
						72.962962962963
Assumptions:
a We have assumed that the average number of existing sources subject to the rule will be seven, which consists of three basic liquid epoxy resins (BLR) plants and four wet strength resins (WSR) plants. There will be no additional new sources per year that will become subject to the rule over the three-year period of this ICR. We assume that each respondent will have to familiarize with the regulatory requirements each year.
b This ICR uses the following labor rates: $144.33 per hour for Executive, Administrative, and Managerial labor; $108.28 per hour for Technical labor, and $53.34 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2016, 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 this is a one-time-only cost. Records for one-time reporting activities must only be retained for five years. The five year period after this initial activities precedes the period covered by this ICR renewal.
d For all wet strength resins (WSR) facilities, as an alternative to implementing the standards for process vents, storage tanks, and wastewater, these facilities may elect to comply with the requirements of 40 CFR part 63, subpart H - leak detection and repair program for equipment leaks. Because it is more cost effective, we have assumed that all WSR facilities will choose to comply with the alternative standard. These facilities are not required to have the continuous monitoring systems (CMS) installed.
e We have assumed that one facility will have a physical or operational change.
f We have assumed that it will require one test each for wastewater and process vents.
g We have assumed that only one facility will have excess emissions.
h We have assumed that there are seven sources that are subject to this regulation, so the number of sources without excess emissions report is six.
i We have assumed that no area sources are expected to become major sources.
j We have assumed that one facility will require a waiver.
k We have assumed that there are three basic liquid resins (BLR) manufacturing facilities.
l We have assumed that these parameters will automatically be recorded with a data logger.
m We have assumed that there are four WSR facilities subject to the rule.
n We have assumed that it will take two hours to record wastewater parameters during the monthly monitoring.
o We have assumed that startup, shutdown, and/or malfunction (SSM) will occur eight times per year for each facility.
p We have assumed that it will take two hours once per year for each facility to maintain records for one deviation from SSM plans.
q We have assumed that it will take each respondent two hours to submit semiannual (SSM) reports. Also quarterly reporting may be reduced to semiannual reporting for sources that are in compliance for one year.
r Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 2: Agency

					2017 Schedule
					48.08	64.8	26.02
Activity	(A) EPA person- hours per occurrence	(B) No. of occurrences per plant per year	(C) EPA person- hours per plant per year (AxB)	(D) Plants per yeara	(E) Technical person- hours per year (CxD)	(F) Management person-hours per year (Ex0.05)	(G) Clerical person-hours per year (Ex0.1)	(H) Cost, $b
Report review
Notification of construction/reconstruction and startup c	2	1	2	0	0	0	0	$0
Notification of physical and operational changes d	2	1	2	1	2	0.1	0.2	$107.84
Notification of anticipated startupc	2	1	2	0	0	0	0	$0
Notification of actual startup c	2	1	2	0	0	0	0	$0
Notification of applicability of the standard new sources c	2	1	2	0	0	0	0	$0
Notification of initial performance test c	2	1	2	0	0	0	0	$0
Report of initial test c	8	1	8	0	0	0	0	$0
Startup, shutdown, malfunction plan c	4	1	4	0	0	0	0	$0
Quality control plan for CMS c	4	1	4	0	0	0	0	$0
Semiannual SSM reports e. f	4	2	8	7	56	2.8	5.6	$3,019.63
CMS summary report for HAP	4	1	4	3	12	0.6	1.2	$647.06
Immediate reports of inconsistent procedures	4	1	4	7	28	1.4	2.8	$1,509.82
Report of monitoring exceedances and periods of noncompliance g	8	4	32	1	32	1.6	3.2	$1,725.50
Report of no excess emission	2	4	8	6	48	2.4	4.8	$2,588.26
Waiver application h	8	1	8	1	8	0.4	0.8	$431.38
TOTAL ANNUAL BURDEN AND COST (rounded)i					214			$10,000
Assumptions:
a We have assumed that the average number of existing sources subject to the rule will be seven, which consists of three liquid epoxy resins (BLR) plants and four wet strength resins (WSR) plants. There will be no additional new sources 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 incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: $64.80 Managerial rate (GS-13, Step 5, $40.50 x 1.6), $48.08 Technical rate (GS-12, Step 1, $30.05 x 1.6), and $26.02 Clerical rate (GS-6, Step 3, $16.26 x 1.6). These rates are from the Office of Personnel Management (OPM) 2017 General Schedule which excludes locality rates of pay.
c We have assumed that this is a one-time-only cost.
d We have assumed that only one facility will conduct some form of physical or operational change.
e We have assumed that there are 7 sources that are subject to this regulation that report semiannually.
f We have assumed that it will take four hour to review semiannual reports.
g We have assumed that one facility will have excess emissions.
h We have assumed that one facility will request a waiver.
i Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.