Burden Calculation Tables

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Overview

Table 1
Table 2

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Sheet 1: Table 1

Table 1: Annual Respondent Burden and Cost – NESHAP for Chemical Preparations Industry (40 CFR Part 63, Subpart BBBBBBB) (Renewal)
Burden Items	(A) Respondent Hours per Occurrence	(B) Number of Occurrences per Respondent per Year	(C) Hours per Respondent per Year (A x B)	(D) Number of Respondents per Year a	(E) Technical Hours per Year (C x D)	(F) Management Hours per Year (E x 0.05)a	(G) Clerical Hours per Year (Ex0.1)a	(H) Total Labor Costs per Year, $b
1. Familiarization with the regulatory requirements	4	1	4	26	104	5.2	10.4	$13,623.17
2. Required activities
a. Initial performance tests c, d	8	1	8	0	0	0	0	$0
b. Engineering calculations or performance guarantees d, e	8	1	8	0	0	0	0	$0		Labor Rates		Notes:
c. Continuous parameter monitoring e, f	8	1	8	0	0	0	0	$0		Management	$147.40	Updated 2/28/19 to match the United States Department of Labor, Bureau of Labor Statistics, June 2018, “Table 2. Civilian Workers, by occupational and industry group
3. Reporting requirements										Technical	$117.92
a. Initial notification that existing facilities are subject to the standard c, g	4	1	4	0	0	0	0	$0		Clerical	$57.02
b. Notification of new area sources c
(1)     Notification of intent to construct/reconstruct	4	1	4	0	0	0	0	$0
(2)     Notification to commence construct/reconstruct	4	1	4	0	0	0	0	$0
(3)     Notification of startup	4	1	4	0	0	0	0	$0
c. Request for compliance extension h	4	1	4	0	0	0	0	$0
d. Notification of initial performance test c, d	2	1	2	0	0	0	0	$0
e. Notification of compliance status c	4	1	4	0	0	0	0	$0
f. Gather information for semiannual reports i	4	2	8	26	208	10.4	20.8	$27,246.34
g. Semiannual compliance reports i	4	2	8	26	208	10.4	20.8	$27,246.34
Subtotal for Reporting Requirements					598			$68,115.84
4. Recordkeeping Requirements
a. Develop a record system c	4	1	4	0	0	0	0	$0
b. Develop a monitoring plan c	4	1	4	0	0	0	0	$0
c. Implement activities								$0
(1)     Record performance tests c	1	1	1	0	0	0	0	$0
(2)     Record periods of target HAP service and deviations	0.5	52	26	26	676	33.8	67.6	$88,550.59
(3)     Continuous parameter monitoring system inspections, calibration and maintenance j	1	12	12	26	312	15.6	31.2	$40,869.50
(4)     Vent collection systems and control inspections	1	12	12	26	312	15.6	31.2	$40,869.50
d. Store, file and maintain records	4	1	4	26	104	5.2	10.4	$13,623.17
5. Time to train personnel	4	1	4	0	0	0	0	$0
6. Prepare for and participate in audits	0	0	0	0	0	0	0	$0
Subtotal for Recordkeeping Requirements					1,615			$183,912.77
TOTAL Labor Burden and Costs (rounded) k					2,210			$252,000
TOTAL Capital and O&M Costs (rounded) k								$390		43	hr/resp
GRAND TOTAL (rounded) k								$252,000
Assumptions:
a. We have assumed that there are approximately 26 respondents subject to the rule, with no new sources expected over the next three-years of this ICR.
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 assume that this is a one-time only activity for new facilities.
d. One-time activity for new and existing facilities after promulgation of final rule. We assume that performance tests are not required for any of the existing facilities to demonstrate compliance with the emission limits. Instead we assume that 50 percent of the industry will have existing performance tests that demonstrate compliance with the emission limits, and the other 50 percent will use performance guarantees or engineering calculations to demonstrate compliance.
e. We assume that all existing facilities will use their existing continuous parameter monitoring equipment or alarms to demonstrate continuous compliance.
f. There is no additional burden for new monitoring equipment because additional add-on control devices are not expected to be needed to demonstrate compliance with the emission limits and facilities are already equipped with equipment to monitor existing control device parameters.
g. Existing facilities must submit notification that they are subject to the standard within 120 days of the effective date of final rule (December 30, 2009).
h We assume that compliance extensions will not be necessary.
i We assume that all respondents will have deviations requiring submittal of compliance reports semi-annually. We assume that semiannual compliance reports will take each respondent 4 hours twice per year to prepare.
j We have assumed that each respondent will take 1 hour 12 times per year to implement the continuous parameter monitoring system inspections, calibration and maintenance activity.
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 Chemical Preparations Industry (40 CFR Part 63, Subpart BBBBBBB) (Renewal)
Burden Items	(A) EPA Hours per Occurrence	(B) Occurrences per Plant per Year	(C) EPA Hours per Plant per Year (AxB)	(D) Plants per Year a	(E) Technical EPA Hours per Year (CxD)	(F) Managerial Hours per Year (Ex0.05)	(G) Clerical Hours per Year (Ex0.1)	(H) Cost per year, $b
1. Familiarization with the regulatory requirements	2	1	2	0	0	0	0	$0.00
2. Required activities
a. Initial performance tests c, d, e	8	1	8	0	0	0	0	$0
b. Review initial performance test reports, performance guarantees, engineering	4	1	4	0	0	0	0	$0
c. Enter and update information into agency recordkeeping system	1	1	1	0	0	0	0	$0		Labor Rates		Notes:
3. Excess emissions – enforcement activities f	N/A									Technical	$65.71	Updated 2/28/19 to match the rates from the Office of Personnel Management (OPM), 2018 General Schedule.
4. Notification requirements										Management	$48.75
a. Review initial notification that existing facilities are subject to the standard c, g	1	1	1	0	0	0	0	$0		Clerical	$26.38
b. Notifications for new area sources h
(1)     Review notification of intent to construct/reconstruct	4	1	4	0	0	0	0	$0
(2)     Review notification of commencement of construction/reconstruction	2	1	2	0	0	0	0	$0
(3) Review notification of startup	2	1	2	0	0	0	0	$0
c. Review request for compliance extension i	2	1	2	0	0	0	0	$0
d. Review notification of initial performance tests c, d, e	1	1	1	0	0	0	0	$0
e. Review notification of compliance status c, j	4	1	4	0	0	0	0	$0
5. Reporting requirements – review semiannual compliance reports k	4	2	8	6.5	52	2.6	5.2	$2,843.02
TOTAL (rounded) l					60			$2,840
Assumptions:
a. We have assumed that there are approximately 26 respondents subject to the rule, with no new sources expected over the next three-years of this ICR. Facilities subject to the NESHAP rules are located in 13 States.
b. This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: 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.
c. We assume that this is a one-time only cost.
d. We assume that EPA technical personnel will observe all performance tests conducted by new sources.
e. We have assumed that not emission tests will need to be performed. Facilities will utilize existing performance tests, performance guarantees, or engineering calculations to demonstrate initial compliance
f. We have assumed that there would be no enforcement activities for the 3-year period covered by this ICR.
g. We assume that existing area source facilities must submit notification that they are subject to and the standard within 120 days of the effective date of the final rule (December 30, 2009).
h There are no new sources expected over the next three years of this ICR.
i We have assumed that compliance extensions will not be necessary.
j Assume that EPA technical personnel will review all of the initial compliance status notifications for new sources.
k We assume that EPA technical personnel will review 25 percent of the semiannual compliance reports.
l Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.