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117.92 |
147.4 |
57.02 |
Updated labor rates |
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Table 1 - Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements of the MACT Floor |
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for Existing Major Sources: Polyvinyl Chloride and Copolymer Manufacturing Units |
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Burden Item |
(A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
(H) |
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Respondent |
Number of |
Hours |
Number of |
Technical |
Management |
Clerical |
Total |
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Hours per |
Occurrences |
Per |
Respondents |
Hours |
Hours |
Hours |
Labor Costs |
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Occurrence |
Per |
Respondent |
Per Year a |
Per Year |
Per Year |
Per Year |
Per Year b |
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(Technical |
Respondent |
Per Year |
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hours) |
Per Year |
(C=A x C |
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(D x E) |
(F x 0.05) |
(F x 0.1) |
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1. |
Applications |
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N/A |
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2. |
Surveys and Studies |
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N/A |
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3. |
Reporting Requirements |
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A. |
Familiarization with Regulatory Requirements e,n |
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320 |
1 |
320 |
15 |
4,800 |
240 |
480 |
$628,762 |
<-- updated to total # of respondents |
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B. |
Required Activities |
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1) Initial performance test, sampling, and report |
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a) Process Vents c,e |
120 |
1 |
120 |
0 |
0 |
0 |
0 |
$0 |
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b) Resins c,g |
36 |
1 |
36 |
0 |
0 |
0 |
0 |
$0 |
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c) wastewater c,h |
8 |
1 |
8 |
0 |
0 |
0 |
0 |
$0 |
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d) uncontrolled wastewater c,h |
40 |
1 |
40 |
0 |
0 |
0 |
0 |
$0 |
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e) heat exchangers c,i |
8 |
1 |
8 |
0 |
0 |
0 |
0 |
$0 |
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f) equipment leaks c,j |
850 |
1 |
850 |
0 |
0 |
0 |
0 |
$0 |
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2) Periodic performance test, sampling, and report |
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a) Process Vents f |
17.1 |
350 |
5985 |
13 |
77,805 |
3,890 |
7,781 |
$10,191,832.56 |
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b) Resins g |
36 |
350 |
12600 |
15 |
189,000 |
9,450 |
18,900 |
$24,757,488 |
<--Updated # of respondents |
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c) wastewater h |
8 |
12 |
96 |
14 |
1,344 |
67 |
134 |
$176,053.25 |
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d) uncontrolled wastehater h |
40 |
1 |
40 |
15 |
600 |
30 |
60 |
$78,595.20 |
<--Updated # of respondents |
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e) heat exchangers i |
8 |
12 |
96 |
14 |
1,344 |
67 |
134 |
$176,053.25 |
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f) equipment leaks j |
43 |
12 |
516 |
15 |
7,740 |
387 |
774 |
$1,013,878.08 |
<--Updated # of respondents |
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3) Establish operating parameters and monitoring plan |
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a) Process Vents c,d,e |
8 |
1 |
8 |
0 |
0 |
0 |
0 |
$0 |
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4) Continuous parameter monitoring |
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a) Initial capital costs (PRD Electronic Monitor) c,ik |
524 |
1 |
524 |
0 |
0 |
0 |
0 |
$0 |
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b) Annualized capital and O&M costs (PRD Electronic Monitor) k |
24 |
1 |
24 |
5 |
120 |
6.00 |
12.00 |
$15,719.04 |
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5) Other requirements |
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a) equipment openings, initial measurement c,o |
1.5 |
1 |
1.5 |
0 |
0 |
0 |
0 |
$0 |
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b) equipment openings, daily measurement o |
1.5 |
350 |
525 |
15 |
7,875 |
393.75 |
787.5 |
$1,031,562 |
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c) gasholders c,p |
24 |
1 |
24 |
0 |
0 |
0 |
0 |
$0 |
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d) storage vessels c,q |
40 |
1 |
40 |
0 |
0 |
0 |
0 |
$0 |
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e) bypasses, initial requirement c,r |
40 |
1 |
40 |
0 |
0 |
0 |
0 |
$0 |
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f) bypasses, ongoing inspection r |
1 |
12 |
12 |
15 |
180 |
9 |
18 |
$23,578.56 |
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C. |
Create Information |
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Incl. in 3.B |
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D. |
Gather Information |
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Incl. in 3.E |
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E. |
Report Preparation |
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1) Initial Notification c,d |
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5 |
1 |
5 |
0 |
0 |
0 |
0 |
$0 |
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2) Batch precompliance report c,d |
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5 |
1 |
5 |
0 |
0 |
0 |
0 |
$0 |
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3) Notification of performance test with test plan c,d |
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10 |
1 |
10 |
0 |
0 |
0 |
0 |
$0 |
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4) Notification of compliance status c,d |
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20 |
1 |
20 |
0 |
0 |
0 |
0 |
$0 |
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5) Compliance report d,k |
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40 |
2 |
80 |
15 |
1,200 |
60 |
120 |
$157,190.40 |
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6) Notice of inspection d |
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5 |
1 |
5 |
15 |
75 |
4 |
8 |
$9,824.40 |
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Subtotal for Reporting Requirements m |
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335,895 |
$38,260,536 |
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4. Recordkeeping Requirements |
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A. Familiarization with Regulatory Requirements |
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Incl. in 3.A |
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B. Implement Activities |
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N/A |
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C. Develop Record System |
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N/A |
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D. Record Information |
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1) Records of process vent requirements d |
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10 |
1 |
10 |
15 |
150 |
8 |
15 |
$19,648.80 |
<--Updated # of respondents |
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2) Records of resin stripper requirements d |
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15 |
1 |
15 |
15 |
225 |
11 |
23 |
$29,473.20 |
<--Updated # of respondents |
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3) Records wastewater requirements d |
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15 |
1 |
15 |
15 |
225 |
11 |
23 |
$29,473.20 |
<--Updated # of respondents |
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4) Records of storage vessel requirements d |
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10 |
1 |
10 |
15 |
150 |
8 |
15 |
$19,648.80 |
<--Updated # of respondents |
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5) Records of equipment leak requirements d |
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25 |
1 |
25 |
15 |
375 |
19 |
38 |
$49,122.00 |
<--Updated # of respondents |
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6) Records of heat exchanger requirements d |
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10 |
1 |
10 |
15 |
150 |
8 |
15 |
$19,648.80 |
<--Updated # of respondents |
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7) Records of other emission sources requirements d |
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10 |
1 |
10 |
15 |
150 |
8 |
15 |
$19,648.80 |
<--Updated # of respondents |
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E. Personnel Training |
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Incl. in 3.B |
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F. Time for Audits |
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N/A |
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Subtotal for Recordkeeping Requirements |
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1,639 |
187,000 |
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45 |
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TOTAL LABOR BURDEN AND COSTS (rounded)s |
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338,000 |
38,400,000 |
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7,511 |
hr per resp |
TOTAL CAPITAL AND O&M COST (rounded)s |
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7,060,000 |
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GRAND TOTAL (rounded)s |
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45,500,000 |
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FOOTNOTES |
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a |
Assumes that, over the next three years, approximately 15 respondents per year will be subject to the standard, and no additional respondents per year will become subject to the standard. |
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b |
Labor rates are $147.40 for managerial, $117.92 for technical, and $57.02 for clerical. These rates from the United States Department of Labor, Bureau of Labor Statistics, September 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 percent to account for the benefit packages available to those employed by private industry. |
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c |
One-time only costs. |
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d |
Cost incurred by a facility regardless of the number of affected units at the plant. |
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e |
There are 15 major sources in the affected source category. |
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f |
15 major sources are expected to perform testing for process vents. OxyVinyls Pedricktown does not operate a process vent control, but rather sends process vent gas streams to Mexichem Pedricktown for control. Like wise, the Wacker Calvert City facility does not operate a process vent control device, but rather sends process vent gas streams to the Westlake Calvert City facility for control. Per VI, it is assumed that performance testing for process vents will take 120 hours per occurrence initially. The initial compliance and operating procedure development for continuous compliance and will take 8 hours. The daily monitoring of parameters will take 5 min per record with 112 records a day across 33 devices in the industry. There are 3 area source and 15 major source subject to this requirement. Therefore, the continuous/daily monitoring will take on avg 17.1 hr per facility per day over 350 day/yr. |
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g |
Per VI, it is assumed that performance testing for process vents will take 4 hours per sample for 9 samples per facility, initially and daily (350 days per year). See continuous monthly sampling & testing of Non-VC TOHAP in O&M section. |
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h |
Per VI, wastewater testing is estimated to take 4 hours per sample for 2 samples per facility. There are 16 wastewater streams for 17 major sources, yields 16/17 wastewater streams per major source that are sampled monthly. There are 5 uncontrolled wastewater streams per source that are sampled annually. See Capital/O&M costs for non-VC TOHAP samples. |
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i |
Per VI, it is assumed that performance testing on heat exchangers will take 4 hours per sample for 2 samples per facility, initially and monthly, for 16 of the 17 major sources. One of the sources relies on another facility to cool the water. |
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j |
For Equipment leaks, VI estimates approx 10,000 components per facility and 5 minutes per component, plus additional time calibration of analytical device for a total of 850 hr per facility. For continuous monitoring, VI assumes 1 hr is required per component for leak repair, if detected. It was assumed that overall continuous compliace of leak monitoring will take 5% of the time with initial monitoring per month. |
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k |
Per VI, the initial performance testing for pressure relief devices (PRD), would take 524 hours per facility. Periodically, corrective action for discharge from a PRD would take 24 hours. It is estimated that 27% of the respondents would experience discharge from a PRD each year. |
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l |
Per VI, Estimated that semi annual compliance reports would take 40 technical hours twice per year. |
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m |
Reporting subtotal does not include capital costs for PRD monitoring system. |
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n |
It will take 8 employees 8 hours per person to read and understand the rule requirements. |
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o |
For Equipment openings, Per VI, 1.5 hr to obtain measurement, initially, daily. |
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p |
Per VI, it will require 24 hr to evaluate compliance options, order materials, monitor installation, and developing O&M procedures. Note: there are only 15 gas holders in the industry among major & area sources. |
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q |
Per VI, 40 hr per facility to develop initial and ongoing compliance, inspection,and maintenance plans and procedures. |
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r |
Per VI, 40 hr per facility for traning, development, and implementation; and it will take 1 hr per month to inspect car seals per facility. |
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s |
Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
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