Burden Calculation Tables

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Overview

Industry
Agency
CAP&O&M

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Sheet 1: Industry

					117.92	147.4	57.02	Increase:Updated labor rates
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
		Respondent	Per Year
		Per Year	(C=A x B)		(C x D)	(E x 0.05)	(E x 0.1)
1. Applications	N/A
2. Surveys and Studies	N/A
3. Reporting Requirements
A. Familiarization with Regulatory Requirements
New sources c,d,l	320	1	320	0	0	0	0	$0
Existing sources e	8	1	8	4	32	1.6	3.2	$4,191.74
B. Required Activities
1) Initial performance test, sampling, and report
a) Process Ventsc,f	120	1	120	0	0	0	0	$0
b) Resinsc,g	36	1	36	0	0	0	0	$0
c) wastewaterc,h	8	1	8	0	0	0	0	$0
d) uncontrolled wastewaterh	40	1	40	0	0	0	0	$0
e) heat exchangersi	8	1	8	0	0	0	0	$0
f) equipment leaksj	850	1	850	0	0	0	0	$0
2) Periodic performance test, sampling, and report
a) Process Ventsf	17.1	350	5,985	4	23,940	1,197.00	2,394.00	$3,135,948.48
b) Resinsg	36	350	12,600	4	50,400	2,520	5,040	$6,601,996.80
c) wastewaterh	8	12	96	4	384	19.2	38.4	$50,300.93
d) uncontrolled wastewaterh	40	1	40	4	160	8	16	$20,958.72
e) heat exchangersi	8	12	96	4	384	19.2	38.4	$50,300.93
f) equipment leaksj	43	12	510	4	2,040	102	204	$267,223.68
3) Establish operating parameters and monitoring plan
a) Process Ventsc,d,f	8	1	8	0	0	0	0	$0
4) Continuous parameter monitoring
a) Initial capital costs (PRD Electronic Monitor)c,k	524	1	524	0	0	0	0	$0
b) Annualized capital and O&M costs (PRD Electronic Monitor)k	24	1	24	1.08	25.92	1.30	2.59	$3,395.31
5) Other requirements
a) equipment openings, initial measurement m	1.5	1	1.5	0	0	0	0	$0
b) equipment openings, daily measurement m	1.5	350	525	4	2,100	105	210	$275,083.20
c) gasholders m	24	1	24	0	0	0	0	$0
d) storage vessels m	40	1	40	0	0	0	0	$0
e) bypasses, initial requirement m	40	1	40	0	0	0	0	$0
f) bypasses, ongoing inspection m	1	12	12	4	48	2.4	5	$6,287.62
C. Create Information	See 3.B
D. Gather Information	See 3.E
E. Report Preparation
1) Initial Notificationc,d	5	1	5	0	0	0	0	$0
2) Batch precompliance reportc,d	5	1	5	0	0	0	0	$0
3) Notification of performance test with test planc,d	10	1	10	0	0	0	0	$0
4) Notification of compliance statusc,d	20	1	20	0	0	0	0	$0
5) Compliance reportd	40	2	80	4	320	16	32	$41,917.44
6) Notice of inspectiond	5	1	5	4	20	1	2	$2,619.84
Reporting Subtotal					91,832			$10,460,224.69
4. Recordkeeping Requirements
A. Familiarization with Regulatory Requirements	See 3.A
B. Implement Activities	N/A
C. Develop Record System	N/A
D. Record Information
1) Records of process vent requirementsd	10	1	10	4	40	2	4	$5,239.68
2) Records of resin stripper requirementsd	15	1	15	4	60	3	6	$7,859.52
3) Records of wastewater requirementsd	15	1	15	4	60	3	6	$7,859.52
4) Records of storage vessel requirementsd	10	1	10	4	40	2	4	$5,239.68
5) Records of equipment leak requirementsd	25	1	25	4	100	5	10	$13,099.20
6) Records of heat exchanger requirementsd	10	1	10	4	40	2	4	$5,239.68
7) Records of other emission sources requirements	10	1	10	4	40	2	4	$5,239.68
E. Personnel Training	See 3.B
F. Time for Audits	N/A
Recordkeeping Subtotal					437			$49,776.96
TOTAL LABOR BURDEN AND COSTS (rounded):n					92,300			$10,500,000
TOTAL CAPITAL AND O&M COSTS (rounded): n								$1,440,000
GRAND TOTAL (rounded): n								$11,900,000	7690	hrs/response
a Assumes that, over the next three years, approximately 4 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 Costs apply only to newly-applicable sources.
d Cost incurred by a facility regardless of the number of affected units at the plant.
e There are 4 area sources in the affected source category.
f 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 on avg 17.1 hr per facility per day over 350 day/yr.										16.969696969697
g 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 Estimated 1 uncontrolled stream and 1 wastewater stripper per facility. 1 wastewater stripper outlet is expected to require monthly testing; 5 uncontrolled stream will require annual testing (per facility). It will take 4 hours per sample for 2 samples per stream.
i It is assumed that performance testing on heat exchangers will take 4 hours per sample for 2 samples per facility, initially and monthly.
j For Equipment leaks, we estimate 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, we assume 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 We assume 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 It will take 8 employees 40 hours per person to read and understand the rule requirements.
m We have included this item based on comments previously provided by the Vinyl Institute.
n Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 2: Agency

				2018	48.75	65.71	26.38		Increase: Update labor rates
Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting Requirements for Existing Area Sources: Polyvinyl Chloride and Copolymer Manufacturing Units
Burden Item	(A) EPA person-hours per occurrence	(B) No. of occurrences per plant per year	(C) EPA person-hours per plant per year (C=AxB)	(D) Plants Per Year a	(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 Cost Per Year b
1. Applications	not applicable
2. Familiarize with Rule Requirements	16	0	0	0	0	0	0	$0
3. Required Activities
A. Observe initial performance testsc	48	0	0	0	0	0	0	$0
B. Excess emissions -- Enforcement Activitiesd	24	0	0	0	0	0	0	$0
C. Create Information	not applicable
D. Gather Information	not applicable
E. Report Reviews
1) Review initial notification	3	0	0	0	0	0	0	$0
2) Review batch precompliance report	5	0	0	0	0	0	0	$0
3) Review notification of performance test	10	0	0	0	0	0	0	$0
4) Review notification of compliance status	40	0	0	0	0	0	0	$0
5) Review compliance report	20	2	40	4	160	8	16	$8,747.76
6) Review notice of inspection	3	1	3	4	12	0.6	1.2	$656.08
F. Prepare annual summary reporte	8	1	8	1	8	0.4	0.8	$437.39
TOTAL (rounded) f					207			$9,840
a Assumes that, over the next three years, approximately 4 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 Assumes no emissions exceedances.
e Assumes four hours per state 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 Monitor3	$375,000	0	$0	$31,772	4	$127,088
VC Ambient monitoring 6				$164,250	4	$657,000
Gas holders	$5,000	0	$0
Periodic Testing
Process Vent Testing	$43,198	0	$0	$99,080	4	$396,320
Resin Sampling and Monitoring1	$1,803	0	$0	$7,212	4	$28,848
Resin: Non-VC TOHAP testing4	$1,950	0	$0	$23,400	4	$93,600
Wastewater Testing2	$491	0	$0	$5,892	4	$23,568
Wastewater Testing: Non-VC TOHAP testing	$650	0	$0	$7,800	4	$31,200
Uncontrolled Wastewater testing	$0	0	$0	$491	4	$1,964
Uncontrolled Wastewater testing: Non-VC TOHAP testing 5	$3,250	0	$0	$3,250	4	$13,000
Equipment Leak Testing	$177,360	0	$0	$16,105	4	$64,420
Total
			$0			$1,440,000
1 Monthly testing ($601 x 12 months = $7,212 per year)
2 Monthly testing ($491 x 12 months = $5,892 per year)
3 The capital cost of the PRD monitor is $15,000 per device, and it is assumed that 25 devices per facility require indicators.
4 The costs of Non-VC TOHAP testing is $650 per sample, and three samples per facility.
5 The costs of Non-VC TOHAP testing is $650 per sample, and five samples per facility.
6 Assumes 3.65 GC monitors per facility with an annual O&M cost of $45,000 per monitor.