Burden Calculation Tables

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Overview

No of Respondents
No of Responses
Capital O&M
IndustryBurden
AgencyBurden

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Sheet 1: No of Respondents

Number of Respondents
	(A)	(B)	(C)	(D)	(E)
Year	Number of New Respondents 1	Number of Existing Respondents	Number of Existing Respondents that keep records but do not submit reports	Number of Existing Respondents That Are Also New Respondents	Number of Respondents
					(E=A+B+C-D)
1	0	8	0	0	8
2	0	8	0	0	8
3	0	8	0	0	8
Average	0	8	0	0	8

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Sheet 2: No of Responses

Total Annual Responses
(A)	(B)	(C)	(D)	(E)
			Number of Existing Respondents That Keep Records But Do Not Submit Reports	Total Annual Responses
Information Collection Activity	Number of Respondents	Number of Responses		E=(BxC)+D
Notification of applicability	0	1	0	0
Notification of construction/reconstruction	0	1	0	0
Notification of actual startup	0	1	0	0
Notification of special compliance requirements	0	1	0	0
Notification of initial performance test	0	1	0	0
Notification of compliance status	0	1	0	0
Excess emissions report	1.6	2	0	3.2
Report of no excess emissions	6.4	2	0	12.8
Quality improvement plan	0	1	0	0
			Total	16

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Sheet 3: Capital 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)
Baghouse Leak Detection	$22,350	0	$0	$750	8	$6,000
Total			$0			$6,000

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Sheet 4: IndustryBurden

					117.92	147.4	57.02
Burden Items	(A) Person hours per occurrence	(B) 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) Managerial person hours per year (Ex0.05)	(G) Clerical person hours per year (Ex0.1)	(H) Total Cost per year, $ b
1. Applications	N/A
2. Survey and Studies	N/A
3. Reporting Requirements c
A. Familiarization with the regulatory requirements	4	1	4	8	32	1.6	3.2	$4,191.74
B. Required Activities
Initial performance test d	421	1	421	0	0	0	0	$0
Repeat performance test d, e	421	0.2	84.2	0	0	0	0	$0
Operations, maintenance, and monitoring plan f	40	1	40	0	0	0	0	$0
COS Testing n				8				$34,400
HCl/HF Testing n				8				$10,400
Phenol and methanol testing n				8				$14,400
C. Create Information	See 3B
D. Gather Existing Information	See 3B
E. Write Reports
Notification of applicability g	2	1	2	0	0	0	0	$0
Notification of construction/ reconstruction g	2	1	2	0	0	0	0	$0
Notification of actual startup g	2	1	2	0	0	0	0	$0
Notification of special compliance requirements g	2	1	2	0	0	0	0	$0
Notification of initial performance test g	2	1	2	0	0	0	0	$0
Notification of compliance status g	2	1	2	0	0	0	0	$0
Request for extension of compliance adjustment to time periods, and changes in information g	2	1	2	0	0	0	0	$0
Report of performance test	See 3B
Excess emissions report h	16	2	32	1.6	51.2	2.56	5.12	$6,706.79
Report of no excess emission i	8	2	16	6.4	102.4	5.12	10.24	$13,413.58
Quality improvement plan j	40	1	40	0	0	0	0	$0
Subtotal for Reporting					213			$83,512.12
4. Recordkeeping Requirements
A. Familiarization with the regulatory requirements	See 3A
B. Plan Activities	See 3E
C. Implement Activities	See 3E
D. Develop Record System	See 3E
E. Time to Enter Information
Records of operating parameters and emissions k	4	52	208	8	1664	83.2	166.4	$217,970.69
F. Time to transmit or disclose information l	0.25	2	0.5	8	4	0.2	0.4	$523.97
G. Time to Train Personnel	N/A
H. Time for Audits	N/A
Subtotal for Recordkeeping					1,918			$218,494.66
Total Labor Burden and Cost (rounded) m					2,130			$302,000		133	hr per resp
Capital and O&M Cost (see Section 6(b)(iii)): m								$6,000
TOTAL COST: m								$308,000
Assumptions:
a We have assumed that the average number of respondents potentially subject to this rule is 8. There will be no additional new sources over the three-year period of this ICR.
b This ICR uses the following labor rates: $147.40 for Managerial, $117.92 for Technical, and $57.02 for Clerical. 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 have assumed that it will take each respondent 4 hours to familiarize with the regulatory requirements.
d We have assumed that it will take 421 hours for each new respondent to complete an initial performance test based on the following: (1.7 sources per plant x 130 hours per source +200 hours for calibration, retesting, sample analysis, etc) for a total of 421 hours.
e We have assumed that 20% of respondents will have to repeat performance test due to failure.
f We have assumed that each of the respondents will take 40 hours to prepare the operation, maintenance, and monitoring plan.
g We have assumed that each of the respondents will take 2 hours to write reports.
h We have assumed that 20% of respondents will each take 16 hours two times per year to write excess emission reports.
i We have assumed that 80% of respondents will take 8 hours two times per year to complete the report for no excess emissions.
j We have assumed that 10% of facilities are required to prepare a quality improvement plan each year.
k We have assumed that each respondent will take 4 hours 52 times per year to enter information.
l We have assumed that it will take each respondent 15 minutes (0.25 hours) two times per year to transmit of disclose information.
m Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
n Performance tests must be completed once every five years. We estimate the annualized compliance testing costs are $59,200 for all 8 facilities ($34,400 for COS test, $10,400 for HCl/HF test, and $14,400 for phenol/methanol test). See EPA-HQ-OAR-2010-1041-0171.pdf

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Sheet 5: AgencyBurden

					48.75	65.71	26.38
Activity	(A) EPA Hours per occurrence	(B) Number of occurrences per Year	(C) EPA Hours per Year (AxB)	(D) Plants per Year a	(E) Technical Hours per Year (CxD)	(F) Managerial Hours per Year (Ex0.05)	(G) Clerical Hours per Year (Ex0.10)	(H) Total cost per year, $ b
Initial performance tests
New or modified facility	40	1	40	0	0	0	0	$0
Repeat performance tests
A. Familiarization with the regulatory requirements c	40	0.2	8	0	0	0	0	$0
Report review
Notification of applicability	2	1		0
Notification of construction/ reconstruction	2	1	2	0	0	0	0	$0
Notification of actual startup	2	1	2	0	0	0	0	$0
Notification of special compliance requirements	1	1	1	0	0	0	0	$0
Notification of initial performance test	2	1	2	0	0	0	0	$0
Notification of compliance status	2	1	2	0	0	0	0	$0
Request for extension of compliance, adjustment to time periods, and changes in information	2	1	2	0	0	0	0	$0
Quality improvement plan d	40	1	40	0	0	0	0	$0
Operations, maintenance, and monitoring plan	40	1	40	0	0	0	0	$0
Report of performance test	40	1	40	0	0	0	0	$0
Excess emissions report e	20	2	40	1.6	64	3.2	6.4	$3,499.10
Report of no excess emissions f	2	2	4	6.4	25.6	1.28	2.56	$1,399.64
Review compliance test reports for COS for cupolas and formaldehyde, phenol, and methanol for collection/curing operations g	8	1	8	8	64	3.2	6.4	$3,499.10
Total Labor Burden and Cost (rounded) h					177			$8,400
Assumptions:
a We have assumed that the average number of respondents potentially subject to this rule is 8. There will be no additional new sources over the three-year period of this ICR.
b This ICR uses the following labor rates: $65.75 for Managerial, $48.75 for Technical, and $26.38 for Clerical. These rates are from the Office of Personnel Management (OPM) “2018 General Schedule” which excludes locality rates of pay.
c We have assumed that 20% of respondents will fail the performance test.
d We have assumed that it will take 40 hours to review the quality improvement plan report.
e We have assumed that 20% of respondents will submit the excess emissions report and it will take 20 hours to review.
f We have assumed that 80% of respondents will sumbit the report of no excess emissions and it will take take 2 hours to review.
g Assumes Agency will review all of the annual reports - including the new COS, phenol, and methanol emissions testing.
h Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.