Burden Tables

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Overview

Industry
Agency
CAP&O&M

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Sheet 1: Industry

								117.92	147.4	57.02	Updated labor rates
Table 1 - Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements of the MACT Floor
for Existing Major Sources: Polyvinyl Chloride and Copolymer Manufacturing Units
Burden Item				(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
				Respondent	Number of	Hours	Number of	Technical	Management	Clerical	Total
				Hours per	Occurrences	Per	Respondents	Hours	Hours	Hours	Labor Costs
				Occurrence	Per	Respondent	Per Year a	Per Year	Per Year	Per Year	Per Year b
				(Technical	Respondent	Per Year
				hours)	Per Year	(C=A x C		(D x E)	(F x 0.05)	(F x 0.1)
1.	Applications			N/A
2.	Surveys and Studies			N/A
3.	Reporting Requirements
	A.	Familiarization with Regulatory Requirements e,n		320	1	320	15	4,800	240	480	$628,762	<-- updated to total # of respondents
	B.	Required Activities
		1) Initial performance test, sampling, and report
			a) Process Vents c,e	120	1	120	0	0	0	0	$0
			b) Resins c,g	36	1	36	0	0	0	0	$0
			c) wastewater c,h	8	1	8	0	0	0	0	$0
			d) uncontrolled wastewater c,h	40	1	40	0	0	0	0	$0
			e) heat exchangers c,i	8	1	8	0	0	0	0	$0
			f) equipment leaks c,j	850	1	850	0	0	0	0	$0
		2) Periodic performance test, sampling, and report
			a) Process Vents f	17.1	350	5985	13	77,805	3,890	7,781	$10,191,832.56
			b) Resins g	36	350	12600	15	189,000	9,450	18,900	$24,757,488	<--Updated # of respondents
			c) wastewater h	8	12	96	14	1,344	67	134	$176,053.25
			d) uncontrolled wastehater h	40	1	40	15	600	30	60	$78,595.20	<--Updated # of respondents
			e) heat exchangers i	8	12	96	14	1,344	67	134	$176,053.25
			f) equipment leaks j	43	12	516	15	7,740	387	774	$1,013,878.08	<--Updated # of respondents
		3) Establish operating parameters and monitoring plan
			a) Process Vents c,d,e	8	1	8	0	0	0	0	$0
		4) Continuous parameter monitoring
			a) Initial capital costs (PRD Electronic Monitor) c,ik	524	1	524	0	0	0	0	$0
			b) Annualized capital and O&M costs (PRD Electronic Monitor) k	24	1	24	5	120	6.00	12.00	$15,719.04
		5) Other requirements
			a) equipment openings, initial measurement c,o	1.5	1	1.5	0	0	0	0	$0
			b) equipment openings, daily measurement o	1.5	350	525	15	7,875	393.75	787.5	$1,031,562
			c) gasholders c,p	24	1	24	0	0	0	0	$0
			d) storage vessels c,q	40	1	40	0	0	0	0	$0
			e) bypasses, initial requirement c,r	40	1	40	0	0	0	0	$0
			f) bypasses, ongoing inspection r	1	12	12	15	180	9	18	$23,578.56
	C.	Create Information		Incl. in 3.B
	D.	Gather Information		Incl. in 3.E
	E.	Report Preparation
		1) Initial Notification c,d		5	1	5	0	0	0	0	$0
		2) Batch precompliance report c,d		5	1	5	0	0	0	0	$0
		3) Notification of performance test with test plan c,d		10	1	10	0	0	0	0	$0
		4) Notification of compliance status c,d		20	1	20	0	0	0	0	$0
		5) Compliance report d,k		40	2	80	15	1,200	60	120	$157,190.40
		6) Notice of inspection d		5	1	5	15	75	4	8	$9,824.40
Subtotal for Reporting Requirements m								335,895			$38,260,536
4. Recordkeeping Requirements
	A. Familiarization with Regulatory Requirements			Incl. in 3.A
	B. Implement Activities			N/A
	C. Develop Record System			N/A
	D. Record Information
		1) Records of process vent requirements d		10	1	10	15	150	8	15	$19,648.80	<--Updated # of respondents
		2) Records of resin stripper requirements d		15	1	15	15	225	11	23	$29,473.20	<--Updated # of respondents
		3) Records wastewater requirements d		15	1	15	15	225	11	23	$29,473.20	<--Updated # of respondents
		4) Records of storage vessel requirements d		10	1	10	15	150	8	15	$19,648.80	<--Updated # of respondents
		5) Records of equipment leak requirements d		25	1	25	15	375	19	38	$49,122.00	<--Updated # of respondents
		6) Records of heat exchanger requirements d		10	1	10	15	150	8	15	$19,648.80	<--Updated # of respondents
		7) Records of other emission sources requirements d		10	1	10	15	150	8	15	$19,648.80	<--Updated # of respondents
	E. Personnel Training			Incl. in 3.B
	F. Time for Audits			N/A
Subtotal for Recordkeeping Requirements								1,639			187,000		45
TOTAL LABOR BURDEN AND COSTS (rounded)s								338,000			38,400,000		7,511	hr per resp
TOTAL CAPITAL AND O&M COST (rounded)s											7,060,000
GRAND TOTAL (rounded)s											45,500,000
FOOTNOTES
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.
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.
c	One-time only costs.
d	Cost incurred by a facility regardless of the number of affected units at the plant.
e	There are 15 major sources in the affected source category.
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.
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.
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.
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.
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.
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.
l	Per VI, Estimated that semi annual compliance reports would take 40 technical hours twice per year.
m	Reporting subtotal does not include capital costs for PRD monitoring system.
n	It will take 8 employees 8 hours per person to read and understand the rule requirements.
o	For Equipment openings, Per VI, 1.5 hr to obtain measurement, initially, daily.
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.
q	Per VI, 40 hr per facility to develop initial and ongoing compliance, inspection,and maintenance plans and procedures.
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.
s	Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 2: Agency

Table 2 - Average Annual EPA Burden and Cost – NESHAP for Polyvinyl Chloride and Copolymers Production (40 CFR Part 63, Subpart HHHHHHH) (Renewal)
								2018:	48.75	65.71	26.38		Increase: Update labor rates
Burden Item					(A)	(B)	(C)	(D)	(E) Technical person-hours per year (E=CxD)	(F) Management person-hours per year (Ex0.05)	(G) Clerical person-hours per year (Ex0.10)	(H)
					EPA person-hours per occurrence	No. of occurrences per plant per year	EPA person-hours per plant per year (C=AxB)	Plants Per Year a				EPA Cost Per Year b
1.	Applications				not applicable
2.	Familiarization with Rule Requirements				15	1	15	0	0	0	0	$0
3.	Required Activities
	A.	Observe initial performance tests c			48	1	48	0	0	0	0	$0
	B.	Excess emissions -- Enforcement Activities d			24	1	24	1.5	36	2	4	$1,968.25
	C.	Create Information			not applicable
	D.	Gather Information			not applicable
	E.	Report Reviews
		1)	Review initial notification		3	1	3	0	0	0	0	$0
		2)	Review batch precompliance report		5	1	5	0	0	0	0	$0
		3)	Review notification of performance test		10	1	10	0	0	0	0	$0
		4)	Review notification of compliance status		40	1	40	0	0	0	0	$0
		5)	Review compliance report		20	2	40	15	600	30	60	$32,804.10	<- Updated # of facilities that are reviewed
		6)	Review notice of inspection		3	1	3	15	45	2	5	$2,460.31	<- Updated # of facilities that are reviewed
	F.	Prepare annual summary report e			4	1	4	8	32	2	3	$1,749.55
4.	Travel expenses: (1 person * 30 hours per year / 8 hours per day * $75 per diem) + ($600 per round trip) =									n/a	per trip	$0
	TOTAL ANNUAL BURDEN AND COST (rounded)f								820			$39,000
FOOTNOTES
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.
b	Labor rates are $65.71 for managerial (GS-13, Step 5, $41.07 + 60%), $48.75 for technical (GS-12, Step 1, $30.47 + 60%), and $26.38 for clerical (GS-6, Step 3, $16.49 + 60%). These rates 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	Assumes EPA personnel attend 20 percent of the initial process vent stack tests.
d	Assume 10% of major source facilities (15) have emission exceedances.
e	Using four hours per state (8 states) to write annual summary report.
f	Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: CAP&O&M

	Capital/Startup vs. Operation and Maintenance (O&M) Costs
	(A)	(B)	(C)	(D)	(E)	(F)	(G)
	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)
	Continuous Parameter Monitoring
	PRD Electronic Monitor 8	$375,000	0	$0	$26,897	15	$403,455
6	VC Ambient monitoring 9				$164,250	15	$2,463,750
	Gas holders	$5,000	0	$0
	Periodic Testing
	Process Vent Testing10	$51,198	0	$0	$99,080	32	$3,170,560	<-- Updated costs and affected Tos.
	Resin Sampling and Monitoring 1	$1,803	0	$0	$7,212	15	$108,180
	Stripped resin: Non-VC TOHAP testing 2	$1,950	0	$0	$23,400	15	$351,000
	Wastewater Testing3	$491	0	$0	$5,892	15	$88,380
	Wastewater: Non-VC TOHAP testing4	$650	0	$0	$7,800	15	$117,000
	Uncontrolled Wastewater testing 5	$0	0	$0	$491	75	$36,825
	Uncontrolled wastewater: Non-VC TOHAP testing 6	$3,250	0	$0	$3,250	15	$48,750
	Equipment Leak Testing	$77,798	0	$0	$18,205	15	$273,075
	Total
				$0			$7,060,000
	1Monthly testing ($601 x 12 months = $7,212 per year)
	2Per VI's comments, the costs of Non-VC TOHAP testing is $650 per sample, and 3 resin samples per facility.
	3Monthly testing ($491 x 12 months = $5,892 per year)
	4Per VI's comments, the costs of Non-VC TOHAP testing is $650 per sample, and one sample per facility.
	5Per VI's comments, there are 5 uncontrolled wastewater streams per source sampled annually.
	6Per VI's comments, the costs of Non-VC TOHAP testing is $650 per sample, and five samples per facility.
	715 facilities are expected to be required to increase stringency of their LDAR programs to 40 CFR Part 63, Subpart UU.
	8 Per VI's comments, the capital cost of the PRD monitor is $15,000 per device, and it is assumed that 25 devices per facility require indicators.
	9 Per VI's comments, there are 71 GC monitors in the industry (3 area source and 15 major source) with an annual O&M cost of $45,000 per monitor.
	10 Per VI's comments, the cost to test one thermal oxidizer in 2018 was $99,080 and there are 32 thermal oxidizers in operation at 15 major source facilities