Burden Calculation Tables

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Overview

Table 1a
Table 1b
Table 2a
Table 2b

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Sheet 1: Table 1a

Table 1a: Annual Respondent Burden and Cost – NSPS for Wool Fiberglass Insulation Manufacturing Plants (40 CFR Part 60, Subpart PPP) (Renewal)
					117.92	147.4	57.02
Burden Items	(A) Hours per Occurrence	(B) Occurrences per Year	(C) Hours per Year (C=AxB)	(D) Respondents per Year a	(E) Technical Hours per Year (E=CxD)	(F) Managerial Hours per Year (F=Ex0.05)	(G) Clerical Hours per Year (G=Ex0.1)	(H) Cost, $ b
1. Applications	N/A
2. Survey and Studies	N/A
3. Reporting Requirements
A. Familiarize with regulatory requirements c	1	1	1	32	32	1.6	3.2	$4,191.74
B. Required activities
Initial performance tests d	72	1	72	0	0	0	0	$0
Repeat performance tests e	72	0.2	14.4	0	0	0	0	$0
C. Create information
D. Gather existing information
E. Write Report
Notification of construction/reconstruction f	2	1	2	0	0	0	0	$0
Notification of actual startup f	2	1	2	0	0	0	0	$0
Notification of physical or operational change f	2	1	2	0	0	0	0	$0
Notification of initial performance test f	2	1	2	0	0	0	0	$0
Report of performance test	See 3B
Semiannual exceedance report g	4	2	8	32	256	12.8	25.6	$33,533.95
Subtotal for Reporting Requirements					331			$37,726
4. Recordkeeping Requirements
A. Familiarize with regulatory requirements c	See 3A
B. Plan activities	See 3B
C. Implement activities	See 3B
D. Develop record system	N/A
E. Time to enter information
40 CFR Part 60, Subpart PPP
Records of operating parameters and emissions h, i	0.25	250	62.5	32	2,000	100	200	$261,984
Records of startups, shutdowns, and malfunctions j	1	1	1	32	32	1.6	3.2	$4,191.74
F. Train Personnel	N/A
G. Audits	N/A
Subtotal for Recordkeeping Requirements					2,337			$266,176
TOTAL LABOR BURDEN AND COST (rounded) k					2,670			$304,000					42	hours per response
TOTAL CAPITAL AND O&M COSTS (rounded) k								$528,000
GRAND TOTAL (rounded) k								$832,000
Assumptions:
a We have assumed that there are approximately 32 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three years..
b This ICR uses the following labor rates: Managerial $147.40 ($70.19 + 110%), Technical $117.92 ($56.15 + 110%), and Clerical $57.02 ($27.15 + 110%). 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. This ICR assumes that Clerical hours are 10% of Technical hours and Managerial hours are 5% of Technical hours.
c We have assumed that all existing respondents will each take one hour to re-familiarize with the regulatory requirements each year.
d We assume that it will take each respondent 72 hours to complete initial performance tests.
e We assume that 20 percent of respondents will have to repeat the initial performance tests due to failures.
f We assume that each respondent will take two hours to prepare notification reports.
g We assume that each respondent will take four hours to prepare semiannual report.
h We assume that 0.25 hours is required to record operating parameters.
i We assume that each respondent will enter operating parameters and emissions records 250 days per year.
j We assume that it will take one hour per year for each respondent to record startups, shutdowns, malfunctions.etc.
k Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 2: Table 1b

Table 1b: Annual Respondent Burden and Cost – NESHAP for Wool Fiberglass Insulation Manufacturing Plants (40 CFR Part 63, Subpart NNN) (Renewal)
					117.92	147.4	57.02
Burden Items	(A) Hours per Occurrence	(B) Occurrences per Year	(C) Hours per Year (C=AxB)	(D) Respondents per Year a	(E) Technical Hours per Year (E=CxD)	(F) Managerial Hours per Year (F=Ex0.05)	(G) Clerical Hours per Year (G=Ex0.1)	(H) Cost, $ b
1. Applications	N/A
2. Survey and Studies	N/A
3. Reporting Requirements
A. Familiarize with regulatory requirements c	8	1	8	10	80	4	8	$10,479.36
B. Required activities
Initial performance tests d	980	1	980	0	0	0	0	$0
Repeat initial performance tests e	980	0.2	196	0	0	0	0	$0
Operations, maintenance, and monitoring plan f	40	1	40	0	0	0	0	$0
C. Create information	8	1	8	10	80	4	8	$10,479.36
D. Gather existing information
E. Write Report
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, adjustments to time periods, and changes in information g, h	2	1	2	0	0	0	0	$0
Report of performance test	See 3B
Excess emissions report h, n	16	2	32	2	64.0	3.2	6.4	$8,383.49
Report of no excess emissions n, l	1	2	2	8	16	0.8	1.6	$2,095.87
Quality improvement plan l	40	1	40	0	0	0	0	$0
Subtotal for Reporting Requirements					276			$31,438
4. Recordkeeping Requirements
A. Familiarize with regulatory requirements c	See 3A
B. Plan activities	See 3B
C. Implement activities	See 3B
D. Develop record system	N/A
E. Time to enter information
Records of operating parameters and emissions n	9	52	468	10	4,680	234	468	$613,042.56
F. Train Personnel	N/A
G. Audits	N/A
H. Time to transmit or disclose information	8	1	8	13	104	5	10.4	$13,623.17						289	hours per response
Subtotal for Recordkeeping Requirements					5,502			$626,666
TOTAL LABOR BURDEN AND COST (rounded) o					5,780			$658,000	8,450	962,000
TOTAL CAPITAL AND O&M COSTS (rounded) o								$93,900	$621,900
GRAND TOTAL (rounded) o								$752,000		$1,584,000
Assumptions:
a We have assumed that there are approximately 10 respondents, with 2 reconstructed sources becoming subject to the rule over the next three years.
b This ICR uses the following labor rates: Managerial $147.40 ($70.19 + 110%), Technical $117.92 ($56.02 + 110%), and Clerical $57.02 ($27.15 + 110%). 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. This ICR assumes that Clerical hours are 10% of Technical hours and Managerial hours are 5% of Technical hours.
c We have assumed that all existing respondents will each take one hour to re-familiarize with the regulatory requirements each year.
d We assume that it will take each respondent 980 hours to complete initial performance tests.
e We assume that 20 percent of respondents will have to repeat the initial performance tests due to failures.
f We assume that each respondent will take 40 hours to prepare the operations, maintenance, and monitoring plan.
g We assume that it will take each respondent two hours to prepare each of the notifications.
h We assume that it will take each respondent one hour to write the extension of compliance; adjustments to time periods, and changes in information reports.
i We assume that it will take each respondent 16 hours to prepare excess emissions reports.
j We assume that 20 percent of respondents are required to prepare excess emissions reports.
k We assume that each respondent will take one hour to prepare no excess emissions reports.
l We assume that 80 percent of respondents will submit the no excess emissions reports.															93900
m We assume that 40 percent of respondents are required to prepare the quality improvement plan.															528000
n We assume that it will take each respondent nine hours each week to record records of operating parameters and emissions.
o Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: Table 2a

Table 2a: Average Annual EPA Burden and Cost – NSPS for Wool Fiberglass Insulation Manufacturing Plants (40 CFR Part 60, Subpart PPP) (Renewal)
					48.75	65.71	26.38
Burden Items	(A) EPA Hours per Occurrence	(B) Occurrences per Year	(C) EPA Hours per Year (C=AxB)	(D) Plants per Year a	(E) Technical Hours per Year (E=CxD)	(F) Managerial Hours per Year (F=Ex0.05)	(G) Clerical Hours per Year (G=Ex0.1)	(H) Cost, $ b
1. Initial performance tests
A. New or modified plant c	24	1	24	0	0	0	0	$0
2. Repeat performance tests			0
A. New or modified plant c, d	24	0.2	4.8	0	0	0	0	$0
3. Report Review
A. New or modified plant
Notification of construction/reconstruction	2	1	2	0	0	0	0	$0
Notification of actual startup	1	1	1	0	0	0	0	$0
Notification of physical or operational change	2	1	2	0	0	0	0	$0
Notification of initial performance test	1	1.2	1.2	0	0	0	0	$0
Review performance test results e	8	1.2	9.6	0	0	0	0	$0
Review semiannual exceedance/no exceedance reports f	2	2	4	32	128	6.4	12.8	$6,998.21
TOTAL COST (rounded) g					147			$7,000
											$12,980
Assumptions:
a We have assumed that there are approximately 32 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three years.
b This ICR uses the following labor rates: Managerial $65.71 (GS-13, Step 5, $41.07 + 60%) , Technical $48.75 (GS-12, Step 1, $30.47 + 60%), and Clerical $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. The rates have been increased by 60 percent to account for the benefit packages available to government employees. This ICR assumes that Clerical hours are 10% of Technical hours and Managerial hours are 5% of Technical hours.
c We have assumed that it will take 24 hours for each new plant to participate in the performance testing.
d We assume that 20 percent of new or modified plants will have to repeat performance test due to failures.
e We assume that each new or modified plant will take eight hour 1.2 times per year to review the performance test results reports.
f We have assumed that each plant will take two hours two times per year to review the semiannual exceedance/no exceedance reports
g Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 4: Table 2b

Table 2b: Average Annual EPA Burden and Cost – NESHAP for Wool Fiberglass Insulation Manufacturing Plants (40 CFR Part 63, Subpart NNN) (Renewal)
					47.62	64.16	25.76
Burden Items	(A) EPA Hours per Occurrence	(B) Occurrences per Year	(C) EPA Hours per Year (C=AxB)	(D) Plants per Year a	(E) Technical Hours per Year (E=CxD)	(F) Managerial Hours per Year (F=Ex0.05)	(G) Clerical Hours per Year (G=Ex0.1)	(H) Cost, $ b
1. Initial performance tests
A. New or modified plant c	40	1	40	0	0	0	0	$0
2. Repeat performance tests
A. New or modified plant c, d	40	0.2	8	0	0	0	0	$0
3. Report Review
A. New or modified plant
Notification of applicability e	2	1	2	0	0	0	0	$0
Notification of construction/reconstruction e	2	1	2	0	0	0	0	$0
Notification of actual startup e	2	1	2	0	0	0	0	$0
Notification of special compliance requirements e	1	1	1	0	0	0	0	$0
Notification of initial performance test e	2	1	2	0	0	0	0	$0
Notification of compliance status e	2	1	2	0	0	0	0	$0
Request for extension of compliance, adjustments to time periods, and changes in information f	2	1	2	0	0	0	0	$0
Report of initial performance test	40	1	40	0	0	0	0	$0
Excess emissions report g	20	2	40	2	80	4.0	8	$4,272.32
Report of no excess emissions h	2	2	4	8	32	1.6	3.2	$1,708.93
Quality improvement plan i	40	1	40	0	0	0	0	$0
Operations, maintenance, and monitoring plan i	40	1	40	0	0	0	0	$0
TOTAL COST (rounded) j					129			$5,980	$13,000
Assumptions:
a We have assumed that there are approximately 10 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three years.
b This ICR uses the following labor rates: Managerial $65.71 (GS-13, Step 5, $41.07 + 60%) , Technical $48.75 (GS-12, Step 1, $30.47 + 60%), and Clerical $26.38 (GS-6, Step 3, $16.49 + 60%). These rates are from the Office of Personnel Management (OPM), 2016 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. This ICR assumes that Clerical hours are 10% of Technical hours and Managerial hours are 5% of Technical hours.
c We have assumed that it will take 40 hours for each new plant to participate in the performance testing.
d We assume that 20 percent of new or modified plants will have to repeat performance test due to failures.
e We assume that each new or modified plant will take two hour once per year to review the notification reports.
f We assume that each new or modified plant will take two hours once per year to completed request.
g We assume that 20 percent of plants will submit excess emissions reports twice per year.
h We assume that 80 percent of plants will submit the no excess emissions report twice per year.
i We assume that it will take 40 hours once per year to review plans.
j Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.