Burden Calculation Tables

1652t10.xlsx

NESHAP for Halogenated Solvent Cleaners/Halogenated Hazardous Air Pollutants (40 CFR Part 63, Subpart T) (Renewal)

Burden Calculation Tables

OMB: 2060-0273

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Overview

Industry
Agency


Sheet 1: Industry

Table 1: Annual Respondent Burden and Cost – NESHAP for Halogenated Solvent Cleaners/Halogenated Hazardous Air Pollutants (40 CFR Part 63, Subpart T) (Renewal)
















117.92 147.4 57.02




Burden Item (A) Person hours per occurrence (B) No. of occurrences per respondent per year (C) Person hours per respondent per year (AxB) (D) Respondents per year a (E) Technical person-hours per year (CxD) (F) Management person-hours per year (Ex0.05) (G) Clerical person-hours per year (Ex0.1) (H) Total cost per year($) b



1. Applications











a. Batch vapor and in-line cleaning machines N/A










b. Batch cold cleaning machines N/A










2. Survey and studies











a. Batch vapor and in-line cleaning machines N/A










b. Batch cold cleaning machines N/A










3. Reporting Requirements











a. Batch vapor and in-line cleaning machines











i. Familiarization with the regulatory requirements c 2 1 2 768 1536 76.8 153.6 $201,203.71



ii. Gather existing information See 3A(iii) 










iii. Write Report








82%

Initial notification report 1 1 1 0 0 0 0 $0
768 batch and in-line vapor machines
Initial compliance report 4 1 4 0 0 0 0 $0
163 cold-cleaning machines
Performance test results d 30 1 30 0 0 0 0 $0



Annual compliance report e 1.5 1 1.5 768 1152 57.6 115.2 $150,902.78
660000 Capital/Startup vs. Operation and Maintenance (O&M) Costs
Report with exceedance f, g 1 4 4 76.8 307.2 15.36 30.72 $40,240.74

Total annual responses
Report with no exceedance f, h 0.5 2 1 691 691.2 34.56 69.12 $90,541.67
768 Annual Compliance Report
b. Batch cold cleaning machines








307.2 Quarterly Exceedance Reports
i. Familiarize with regulatory requirements i 0.5 1 0.5 163 81.5 4.075 8.15 $10,676
1382 Semiannual exceedance reports
ii. Gather existing information See 3B(iii) 







163 Batch cold cleaning - recordkeeping
iii. Write Report j








2620

Initial notification report 0.25 1 0.25 0 0 0 0 $0



Initial compliance report 0.25 1 0.25 0 0 0 0 $0



Subtotal for Reporting Requirements



4,333.09 $493,564.76



4. Recordkeeping Requirements











a. Batch vapor and in-line cleaning machines











i. Familiarization with the regulatory requirements See 3A(i) 










ii. Plan activities N/A










iii. Implement activities











Performance test d 50 1 50 0 0 0 0 $0



Control device monitoring k, l 1.64 12 19.68 384 7557.12 377.856 755.712 $989,922.26



Solvent consumption log m 1.5 12 18 384 6912 345.6 691.2 $905,416.70



iv. Record Data











Control device monitoring l, n 1.2 12 14.4 384 5529.6 276.48 552.96 $724,333.36



Solvent emission calculation m, o 0.75 12 9 384 3456 172.8 345.6 $452,708.35



v. Time to train personnel p











b. Batch cold cleaning machines N/A










Subtotal for Recordkeeping Requirements



26,973 3,072,381



TOTAL ANNUAL BURDEN AND COST (rounded) q 31,300 $3,570,000

12 hr per resp
Capital and O&M Cost (see Section 6(b)(iii)): q






$660,000



TOTAL COST: q






$4,230,000





























Assumptions:











a. We estimate that an average of 931 existing respondents will be subject to the rule over the three-year period of this ICR. Of this total, 768 respondents are subject to batch vapor and in-line cleaning machine requirements while 163 respondents are subject to batch cold cleaning machine requirements. No new respondents are expected.











b. This ICR uses the following labor rates: $117.92 for technical, $147.40 for managerial, and $57.02 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 percent to account for the benefit packages available to those employed by private industry.











c. We assume it will take 2 hours to read instructions.











d. We estimate that idling emission or dwell test reports will require 80 technical hours, which are divided between the test report (30 hours) and the test itself (50 hours).











e. We assume that 768 facilities are required to complete the annual compliance report.











f. The burden of one quarterly and one semiannual exceedance report is included in the burden estimate for the annual report.











g. We assume that 10 percent of 768 facilities are in exceedance at least one time per year (quarterly reporting).











h. We assume that 90 percent of 768 facilities are not in exceedance (semiannual reporting).











i. We assume that it will take 0.5 hours to read instructions.











j. We assume that it will take 0.25 hours to write each report.











k. Actual monitoring is conducted weekly, monthly or quarterly for specific control devices. The estimated time is based on the typical control devices expected to be installed.











l. We assume that 50 percent of the facilities will choose the standard equipment and will be required to conduct control device monitoring.











m. We assume that 50 percent of the facilities will choose to do solvent consumption monitoring.











n. We assume that it would take 1.2 hours per facility to record data.











o. We assume that it would take 0.75 hours per facility to record solvent consumption data.











p. We assume that no special training requirements are required.











q. Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.












Sheet 2: Agency

Table 2: Average Annual EPA Burden and Cost – NESHAP for Halogenated Solvent Cleaners/Halogenated Hazardous Air Pollutants (40 CFR Part 63, Subpart T) (Renewal)












48.75 65.71 26.38
Burden Item (A) Technical person-hours per occurrence (B) No. of occurrences per respondent per year (C) Technical person-hours per respondent per year (AxB) (D) Respondents per year (E) Technical hours per year (CxD) (F) Management hours per year (Ex0.05) (G) Clerical hours per year (Ex0.1) (H) Total cost per year($) a
Report Activity







1. Batch vapor and in-line cleaning machine







a. Initial notification report 1 1 1 0 0 0 0 $0
b. Initial compliance report 2 1 2 0 0 0 0 $0
c. Performance test results b 8 1 8 0 0 0 0 $0
d. Annual compliance report c 2 1 2 768 1536 76.8 153.6 $83,978.50
Report with exceedance d, e 1 4 4 76.8 307.2 15.36 30.72 $16,795.70
Report with no exceedance d, f 0.5 2 1 691 691.2 34.56 69.12 $37,790.32
2. Batch Cold Cleaning Machines







a. Initial notification/compliance report 0.25 1 0.25 0 0 0 0 $0
TOTAL ANNUAL BURDEN AND COST (rounded) g 2,910 $139,000


















Assumptions:







a. This ICR uses the following labor rates: $48.75 for technical, $65.71 for managerial, and $26.38 for clerical labor. 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.







b. We assume that it will take 8 hours to review performance test results.







c. All facilities are expected to submit annual compliance reports summarizing either solvent consumption data or monitoring results for each cleaning machine.







d. The burden of one quarterly and one semiannual exceedance report is included in the burden estimate for the annual report.







e. We assume that 10 percent of 768 facilities are in exceedance at least one time per year.







f. We assume that 90 percent of 768 facilities are not in exceedance.







g. Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.







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