NESHAP for Carbon Black, Ethylene, Cyanide, and Spandex (40 CFR Part 63, Subpart YY) (Renewal)

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Overview

Table 1
Table 2
O&M

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Sheet 1: Table 1

Table 1: Annual Respondent Burden and Cost - NESHAP for Carbon Black, Ethylene, Cyanide, and Spandex (40 CFR Part 63, Subpart YY) (Renewal)
REPORTING / RECORDKEEPING REQUIREMENT	(A) Person-hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person-hours per respondent (C=AxB)	(D) Respondents per yeara	(E) Technical person-hours (E=CxD)	(F) Managerial person-hours (Ex0.05)	(G) Clerical person-hours (Ex0.10)	(H) Cost, $b
1. APPLICATIONS	N/A
2. SURVEY AND STUDIES	N/A
3. REPORTING REQUIREMENTS
a. Familiarization with Regulatory Requirements	1	1	1	61	61	3.05	6.1	$7,681.64
b. Required Activities
Initial Performance Tests	57	1	57	0	0	0	0	$0
Repeat of Performance Testsc	57	0.1	5.7	0	0	0	0	$0
Startup, Shutdown and Malfunction Plan	40	1	40	61	2,440	122	244	$307,265.54
c. Create Information	See 3b
d. Gather Existing Information	See 3b
e. Write Report
Initial Notification of Applicability	2	1	2	0	0	0	0	$0
Notification of Construction/Reconstruction	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 Dates	2	1.1	2.2	0	0	0	0	$0
Notification of Operating Parameter Value and Rationale Selection	2	1	2	0	0	0	0	$0
Notification of Compliance Status	2	1	2	0	0	0	0	$0
Report of Initial Performance Test Results	8	1.1	8.8	0	0	0	0	$0
Reporting Results of Continuous Monitoring System Performance Report and Summary Report	See 3b
Periodic and Semiannual Reports	8	2	16	61	976	48.8	97.6	$122,906.22
Excess Emissions and Continuous Monitoring System Performance Report and Summary Reportd	8	2	16	61	976	48.8	97.6	$122,906.22
Immediate Startup, Shutdown, Malfunction Reportse	4	1	4	3	12	0.6	1.2	$1,511.14
Request for Waiver of Reporting and Recordkeeping	4	1	4	0	0	0	0	$0
Reporting Subtotal					5,135			$562,270.75
4. RECORDKEEPING REQUIREMENTS
a. Familiarization with Regulatory Requirements	See 3b
b. Plan Activities	See 3b
c. Implement Activities	See 3b
d. Develop Record System	N/A
e. Time to Enter Information
Records of SS&M	1.5	52	78	61	4,758	237.9	475.8	$599,167.80
Records of CMS	1	365	365	61	22,265	1,113.25	2,226.5	$2,803,798.05
Collect and compile data	24	2	48	61	2,928	146.4	292.8	$368,718.65
Enter / verify information for semiannual reports	16	2	32	61	1,952	97.6	195.2	$245,812.43
f. Train Personnel	N/A
g. Audits	N/A
Recordkeeping Subtotal					36,688			$4,017,496.94
TOTAL LABOR BURDEN AND COSTS (rounded)f					41,800			$4,580,000
TOTAL CAPITAL AND O&M COST (rounded)f								$351,000
GRAND TOTAL (rounded)f								$4,930,000
									No. responses	247
									hr/response	169
Assumptions:
a We have assumed that there are approximately 61 respondents, consisting of 18 manufacturing carbon black, 14 manufacturing cyanide, 26 manufacturing ethylene, and 3 manufacturing spandex, with no additional new or reconstructed sources becoming subject to the rule over the next three years.
b This ICR uses the following labor rates: $112.98 (technical), $149.35 (managerial), and $54.81 (clerical). These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2017, “Table 2. Civilian workers, by occupational and industry group.” The rates are from column 1, “Total compensation.” They have been increased by 110 percent to account for the benefit packages available to those employed by private industry.
c We have assumed that the rate of failed performance tests is 10%.
d Includes periodic startup, shutdown and malfunction report.
e We have assumed that only 5% (3) respondents per year will need to submit an immediate SSM report.
fTotals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 2: Table 2

Table 2: Annual Agency Burden and Cost - NESHAP for Carbon Black, Ethylene, Cyanide, and Spandex (40 CFR Part 63, Subpart YY) (Renewal)
REPORTING/RECORDKEEPING REQUIREMENT	(A) Person-hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person-hours per respondent (C=AxB)	(D) Respondents per yeara	(E) Technical person-hours (E=CxD)	(F) Managerial person-hours (Ex0.05)	(G) Clerical person-hours (Ex0.10)	(H) Cost, $b
			(A) x (B)		(C) x (D)	(E) x 0.05	(E) x 0.10
INITIAL PERFORMANCE TESTS
New or Modified Facility	5	1	5	0	0	0	0	$0
Repeat of Performance Tests	5	0.1	0.5	0	0	0	0	$0
REPORT REVIEW
Notification of Applicability	2	1	2	0	0	0	0	$0
Notification of Construction/Reconstruction	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
Request for Extension of Compliance	2	1	2	0	0	0	0	$0
Notification of Special Compliance Requirements	2	1	2	0	0	0	0	$0
Notification of Performance Test Dates	2	1.1	2.2	0	0	0	0	$0
Notification of Operating Parameter Value and Rationale Selection	2	1	2	0	0	0	0	$0
Notification of Compliance Status	2	1	2	0	0	0	0	$0
Review Report of Initial Performance Test	5	1.1	5.5	0	0	0	0	$0
Review Reporting Results of Continuous Monitoring System Performance Report and Summary Report	Included in Review of Performance Test Report
Review Periodic & Semiannual Reports	5	2	10	61	610	30.5	61	$32,892.42
Review Excess Emission Report and Continuous Monitoring System Performance Report and Summary Reportc	20	2	40	61	2,440	122	244	$131,569.68
Review Immediate Startup, Shutdown, Malfunction Report	8	1	8	3	24	1.2	2.4	$1,294.13
Review Request for Waiver of Reporting and Recordkeeping	2	1	2	0	0	0	0	$0
Subtotal					3,074	153.7	307.4	$165,756.23
TOTAL ANNUAL BURDEN AND COST (rounded)c					3,540			$166,000
a We have assumed that there are approximately 61 respondents, consisting of 18 manufacturing carbon black, 14 manufacturing cyanide, 26 manufacturing ethylene, and 3 manufacturing spandex, with no additional new or reconstructed sources becoming subject to the rule over the next three years.
b This ICR uses the following labor rates: $48.08 (technical), $64.80 (managerial), and $26.02 (clerical). These rates are from the Office of Personnel Management (OPM), 2017 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 Includes review of periodic startup, shutdown and malfunction report.
d We have assumed that only 5% (3) respondents per year will need to submit an immediate SSM report.
e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: O&M

Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A)	(B)	(C)	(D)	(E)	(F)	(G)
Source Category with 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)
CB	N/A	0	$0	$9,545	18	$171,810
CY	N/A	0	$0	$9,545	14	$133,630
ET	N/A	0	$0	$734	26	$19,084
SP	N/A	0	$0	$8,811	3	$26,433
TOTAL	-	0	$0	-	61	$351,000