Burden Calculation Tables

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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 Reinforced Plastic Composites Production (40 CFR Part 63, Subpart WWWW) (Renewal)
					117.92	147.4	57.02
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 (C=AxB)	Respondents per year a	Technical person- hours per year (E=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. Acquisition, Installation, and Utilization of Technology and Systems	N/A
4. Reporting Requirements
A. Familiarization with Regulatory Requirementsc
i. Facilities with 4 groups of operations	1.00	1	1	416.64	416.64	20.83	41.66	$54,576.5	Updated to apply to add resopndents, adjusted hours from 12 to 1 since it will take less time for sources to familiarize themselves with the rule.
ii. Facilities with 5 groups of operations	1.25	1	1	31.36	39.20	1.96	3.92	$5,134.9	Updated to apply to add resopndents, adjusted hours from 13 to 1.25 since it will take less time for sources to familiarize themselves with the rule.
B. Required activities: Sources with add-on controls
i. Initial performance test d	320	1	320	0	0	0	0	$0	Removed new respondents
ii. Repeat of performance test	320	1	320	0	0	0	0	$0	Removed new respondents
iii. Operation, maintenance, monitoring plan	40	1	40	0	0	0	0	$0	Removed new respondents
iv. Startup, shutdown, malfunction plan	20	1	20	0	0	0	0	$0	Removed new respondents
v. Monitoring of operating parameters and equipment e	See 5E
C. Gather Existing Information	See 5D, 5E
D. Write report a
i. Notification of compliance status d	4	1	4	0	0	0	0	$0	Removed new respondents
ii. Notification of construction/ reconstruction a, d	2	1	2	0	0	0	0	$0	Removed new respondents
iii. Notification of actual startup d	2	1	2	0	0	0	0	$0	Removed new respondents
iv. Notification of performance test d	2	1	2	0	0	0	0	$0	Removed new respondents
v. Reports of performance test results	See 4B
vii. Report of exceedances g	16	2	32	89.60	2867.20	143.36	286.72	$375,580.3	Updated # of respondents based on new inventory and prior percentaage assumptions
viii. Report of no exceedances g	8	2	16	358.40	5734.40	286.72	573.44	$751,160.52	Updated # of respondents based on new inventory and prior percentaage assumptions
ix. Startup, shutdown, malfunction report h	2	1	2	14.00	28.00	1.40	2.80	$3,668	Updated # of respondents based on new inventory and prior percentaage assumptions
Subtotal for Reporting Requirements					10,448			$1,190,120
5. Recordkeeping Requirements
A. Familiarization with Regulatory Requirements	See 4A
B. Plan activities	See 4B
C. Implement activities	See 4B
D. Develop record system (spreadsheets): i
i. System for low HAP resin	4	1	4	0	0	0	0	$0	Removed new respondents
ii. System for work practices	1	1	1	0	0	0	0	$0	Removed new respondents
iii. System for add-on control devices	2	1	2	0	0	0	0	$0	Removed new respondents
E. Time to enter and transmit all information into record system i
i. Enter information on low HAP resin	10	1	10	358	3580	179	358	$468,951.36	Updated # of respondents based on new inventory and prior percentaage assumptions
ii. Enter information on work practices and operating parameters	N/A
F. Develop operator training course and keep records of operators taken it d	10	1	10	0	0	0	0	$0
G. Time to train personnel: j
i. Small facilities (less than 100 employees)	2	1	2	0	0	0	0	$0	Removed new respondents
	0.4	1	0.4	367.36	146.94	7.35	14.69	$19,248.49	Updated # of respondents based on new inventory and prior percentaage assumptions
ii. Medium facilities (100-250 employees)	4	1	4	0	0	0	0	$0	Removed new respondents
	0.8	1	0.8	49.28	39.42	1.97	3.94	$5,164.23	Updated # of respondents based on new inventory and prior percentaage assumptions
iii. Large facilities (more than 250 employees)	8	1	8	0	0	0	0	$0	Removed new respondents
	1.6	1	1.6	31.36	50.18	2.51	5.02	$6,572.65	Updated # of respondents based on new inventory and prior percentaage assumptions
H. Time for audits	N/A
Subtotal for Recordkeeping Requirements					4,389			$499,937
TOTAL LABOR BURDEN AND COST (rounded)k:					14,800			$1,690,000
Capital and O&M Cost (rounded)k:								$468,000
TOTAL COST (rounded)k:								$2,160,000
Assumptions:
a There is an average of 448 existing reinforced plastic composites facilities (or RPC) subject to NESHAP subpart WWWW. We have assumed that there will be no new RPC facilities each year over the three year period of this ICR. We have assumed that 82 percent of the existing RPC facilities are small business, 11 percent are medium size facilities and 7 percent are large facilities. Furthermore, we have assumed that 93 percent of the new RPC facilities will consist of an average of four groups of operations and 7 percent will consist of five groups of operations.											16	hrs/reponse
b This ICR uses the following labor rates: $147.40 per hour for Executive, Administrative, and Managerial labor; $117.92 per hour for Technical labor, and $57.02 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2018, ”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 93% of respondents have 4 groups of operations and 7% of respondents have 5 groups of operations.
d We have assumed no new respondents over the next three years due to trends in industry consolidation. Because there are no new respondents, we expect no burden for this requirement.
e Monitoring and recordkeeping of operations for respondents with enclosures and add-on control devices include: 1) specific operating parameters for each control device established during the performance test, 2) start-up, shutdown, and malfunctions of equipment, and 3) work practices.
f Monitoring and recordkeeping of operations for respondents that comply by limiting the HAP content of their raw materials include: 1) monitoring and recording in a spreadsheet the monthly consumption of material and the weighted-average HAP content over the past 12 months, and 2) work practices. However, if all the materials in an operation meet the HAP content limit, then each respondent would need only to record HAP content and would not need to track monthly consumption or record the computations. For open molding and centrifugal casting operations, respondents would also have the option of averaging among thirteen different processes (open molding) and two different processes (centrifugal casting to calculate the monthly average of the actual and allowable emissions for the combined open molding and centrifugal casting operations).
g We have assumed that approximately 80 percent of the 448 (or 358.4) existing respondents will report no excess emissions twice a year and approximately 20 percent (or 89.6) will report excess emissions twice a year.
h We have assumed that all RPC facilities with add-on controls (approximately 3% or 14 facilities) will have at least one startup, shutdown or malfunction (SSM) that is not managed according to the SSM plan.
i New respondents (0) would be required to develop a record system and existing respondents would be required to record operational data. For existing respondents, the following monitoring is required: 1) facilities with open molding and/or centrifugal casting operations 358 (approximately 80% of facilities) would have to record for low HAP resins; 2) facilities with add-on controls (14 existing RPCs per year) would have to record add-on control devices operating parameters; and 3) all facilities (448) need to keep records of its work practices. Since operating parameters for control equipment and standard work practices are already monitored by industry for other purposes, we are not attributing these burdens to the rule.
j We have assumed that the amount of time it takes a respondent to train its employees would vary with the number of employees at its facility. We have also assumed that the distribution in size of the new respondents would be identical to that of the existing RPC universe. Therefore, we have assumed that 82 percent of the respondents would be small business (i.e., 380.8 existing RPCs per year, 11 percent (i.e. 49.28 existing RPCs per year), would be medium business, and 7 percent (i.e., 31.36 existing RPCs) are large business. Furthermore, we have assumed that respondents will only provide full training to new employees (0 respondents); we assume that, for existing respondents, it will take 20 percent of the time it takes to train new employees.
k Totals 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: Average Annual EPA Burden and Cost – NESHAP for Reinforced Plastic Composites Production (40 CFR Part 63, Subpart WWWW) (Renewal)
					48.75	65.71	26.38
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 (C=AxB)	Respondents per year a	Technical person- hours per year (E=CxD)	Management person hours per year (Ex0.05)	Clerical person hours per year (Ex0.1)	Cost, $ b
Notification of applicability a	2	1	2	0	0	0	0	$0	Removed new respondents
Notification of intent to construct a major source and review application	12	1	12	0	0	0	0	$0	Removed new respondents
Notification of start of construction	2	1	2	0	0	0	0	$0	Removed new respondents
Notification of actual startup	2	1	2	0	0	0	0	$0	Removed new respondents
Notification of initial performance test and test plan	12	1.2	14.4	0	0	0	0	$0	Removed new respondents
Report of performance test results including operating parameters	12	1.2	14.4	0	0	0	0	$0	Removed new respondents
Notification of compliance status	2	1	2	0	0	0	0	$0	Removed new respondents
Review reports of excess emissions c	4	2	8	89.6	716.8	4.48	71.68	$37,129.30	Updated # of respondents based on new inventory and prior percentaage assumptions
Review reports of no excess emissions c	2	2	4	358.4	1433.6	17.92	143.36	$74,847.36	Updated # of respondents based on new inventory and prior percentaage assumptions
Review of startup, shutdown, malfunction report d	4	1	4	14	56	0.7	5.6	$2,923.73	Updated # of respondents based on new inventory and prior percentaage assumptions
TOTAL ANNUAL BURDEN AND COST (rounded)e					2,450			$115,000
Assumptions:
a There is an average of 448 existing reinforced plastic composites facilities (or RPC) subject to NESHAP subpart WWWW. We have assumed that there will be no new RPC facilities each year over the three year period of this ICR. We have assumed that 82 percent of the existing RPC facilities are small business, 11 percent are medium size facilities and 7 percent are large facilities. Furthermore, we have assumed that 93 percent of the new RPC facilities will consist of an average of four groups of operations and 7 percent will consist of five groups of operations.
b This cost is based on the following labor rates: Managerial rate of $65.71 (GS-13, Step 5, $41.07 + 60%), Technical rate of $48.75 (GS-12, Step 1, $30.47 + 60%), and Clerical rate of $26.38 (GS-6, Step 3, $16.49 + 60%). These rates are from the Office of Personnel Management (OPM), 2018 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 that approximately 80 percent (or 358.4) of the respondents will report no excess emissions twice a year and approximately 20 percent (or 89.6) will report excess emissions twice a year.
d We have assumed that all RPC facilities with add-on controls (3% or 14 existing facilities) will have at least one startup, shutdown, or malfunction occurrence that is not managed according to the plan.
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)
Continuous Monitoring Device 1	Capital/Startup Cost for One Respondent	Number of New Respondents	Total Capital/Startup Cost, (B X C)	Annual O&M Costs for One Response	Number of Responses / Source	Total O&M, (E X F)
N/A 2	0	0	0	$20.13	910	$18,318
SMC enclosure 3				$450,000	1	$450,000
Total (Rounded) 4						$468,000