Burden Calculation Tables

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Overview

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

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Sheet 1: IndustryBurden

Table 1: Annual Respondent Burden and Cost – NESHAP for Commercial Ethylene Oxide Sterilization and Fumigation Operations (40 CFR Part 63, Subpart O) (Renewal)
Burden Items	(A) Hours per occurrence	(B) Occurrences per year	(C) Hours per year (AxB)	(D) Respondents 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
1. Applications	N/A									Technical	Management	Clerical
2. Survey and Studies	N/A									$120.27	$141.06	$58.67
3. Reporting Requirements
A. Familiarization with the regulatory requirements	1	1	1	128	128	6.4	12.8	$17,048.32
B. Required Activities
Initial performance test c	200	1	200	2	400	20	40	$53,276.00
Repeat performance test c, d	200	1	200	0.4	80	4	8	$10,655.20
Preparation of site-specific test plan	Included Above
C. Create Information	See 3B
D. Gather Existing Information	See 3B
E. Write Reports
Notification of applicability e	2	1	2	2	4	0.2	0.4	$532.76
Notification of construction/reconstruction e	2	1	2	2	4	0.2	0.4	$532.76
Notification of actual startup e	2	1	2	2	4	0.2	0.4	$532.76
Notification of initial performance test e	2	1	2	2	4	0.2	0.4	$532.76
Notification of compliance status e	2	1	2	2	4	0.2	0.4	$532.76
Request for extension of compliance, adjustment to time periods, and changes in information	2	1	2	0	0	0	0	$0
Request for waiver f	6	1	6	0.2	1.2	0.06	0.12	$159.83
Report for alternative method monitoring g	6	1	6	0.1	0.6	0.03	0.06	$79.91
Report for performance test h	24	1	24	2	48	2.4	4.8	$6,393.12
Reports for periods of noncompliance (including excess emissions) i	14	2	28	115	3,220	161	322	$428,871.80
Subtotal for Reporting					4,482			$519,147.98
4. Recordkeeping Requirements
A. Familiarization with the regulatory requirements	See 3A
B. Plan Activities	See 3B
C. Implement Activities	See 3B
D. Develop Record System	See 3B
E. Time to Enter Information
Record of operating parameters and emissions j	0.1	365	36.5	115	4,198	209.875	419.75	$559,065.03
Records of EO use k	0.6	12	7.2	12	86.4	4.32	8.64	$11,507.62
F. Time to transmit or disclose information l	0.25	2	0.5	115	57.5	2.875	5.75	$7,658.43
G. Train Personnel	N/A
H. Time for Audits	N/A
Subtotal for Recordkeeping					4,993			$578,231.07		254	# responses
Total Labor Burden and Costs (rounded) m					9,480			$1,100,000		37	hr per resp
Total Capital and O&M Cost (rounded) m								$698,000
Grand Total (rounded) m								$1,800,000
Assumptions:
a There are an average of 128 respondents subject to the rule over the three-year period of this ICR. Two additional new sources per year are expected to become subject to the rule over the three-year period of this ICR.
b This ICR uses the following labor rates for privately-owned sources: $141.06 for managerial, $120.27 for technical, and $58.67 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2019, “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 Assumes it will take 200 hours for each respondent to perform the initial and any repeat performance testing.
d Assumes that 20 percent of respondents will have to repeat performance tests due to failure.
e Assumes that it will take new respondents two hours to write each notification report.
f Assumes that 10 percent of new facilities will request a waiver and that it will take 6 hours to write requests for waivers.
g Assumes that 5 percent of new facilities will request an alternative monitoring method.
h Assumes that it will take 24 hours to prepare performance test reports.
i Assumes that 115 respondents will take 14 hours each to complete reports of periods of noncompliance, which includes excess emissions. This will occur two times per year.
j Assumes that 115 respondents will enter information on record of operating parameters and emissions 365 times per year.
k Assumes that 12 affected facilities are only required to record EO usage and that that each of the 12 respondents will record EO use 12 times per year.
l Assumes that 115 respondents will submit reports twice per year.
m Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 2: AgencyBurden

Table 2: Average Annual EPA Burden and Cost – NESHAP for Commercial Ethylene Oxide Sterilization and Fumigation Operations (40 CFR Part 63, Subpart O) (Renewal)
Activity	(A) EPA Hours per Occurrence	(B) 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										Technical	Management	Clerical
New or modified facility c	40	1	40	2	80	4	8	$4,435.68		$49.44	$66.62	$26.75
Repeat performance tests
New or modified facility d	40	1	40	0.4	16	0.8	1.6	$887.14		changed this from 136 to 40 hours
Report Review
New or modified facility
Notification of applicability	2	1	2	2	4	0.2	0.4	$221.78
Notification of construction/reconstruction e	2	1	2	2	4	0.2	0.4	$221.78
Notification of actual startup e	2	1	2	2	4	0.2	0.4	$221.78
Notification of initial performance test e	2	1	2	2	4	0.2	0.4	$221.78
Notification of compliance status e	2	1	2	2	4	0.2	0.4	$221.78
Request for extension of compliance, adjustment to time periods, and changes in information f	2	1	2	2	4	0.2	0.4	$221.78
Request for waiver g	4	1	4	0.2	0.8	0.04	0.08	$44.36
Request for alternative method/monitoring h	4	1	4	0.1	0.4	0.02	0.04	$22.18
Report of performance test i	8	1	8	2	16	0.8	1.6	$887.14
Report of periods of noncompliance (including excess emissions) j	8	2	16	23	368	18.4	36.8	$20,404.13
Total (rounded) k					581			$28,000
Assumptions:
a There are an average of 128 respondents subject to the rule over the three-year period of this ICR. Two additional new sources per year are expected to become subject to the rule over the three-year period of this ICR.
b This ICR uses the following labor rates: $66.62 for managerial, $49.44 for technical, and $26.75 for clerical labor. These rates are from the Office of Personnel Management (OPM), 2019 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 that the Agency will take 40 hours to observe the initial performance test.
d Assumes that 20 percent of new respondents will fail the performance test and will have to repeat it.
e Assumes that the Agency will take two hours to review each notification report.
f Assumes that the Agency will take two hours to review each request for extension of the compliance report.
g The Agency assumes that 10 percent of new facilities will request a waiver.
h The Agency assumes that 5 percent of new facilities will request an alternative method monitoring.
i Assumes that the Agency will take 8 hours to review the report of performance test results.
j Assumes the Agency will review 20 percent of noncompliance reports and that it will take the Agency 8 hours to review reports of periods of noncompliance.
k Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: 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	2	114	12	1	127
2	2	115	12	1	128
3	2	116	12	1	129
Average	2	115	12	1	128

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Sheet 4: No of Responses

Total Annual Responses
(A)	(B)	(C)	(D)	(E)
Information Collection Activity	Number of Respondents	Number of Responses	Number of Existing Respondents That Keep Records But Do Not Submit Reports	Total Annual Responses
				E=(BxC)+D
Notification of Applicability	2	1	0	2
Notification of Construction/Reconstruction	2	1	0	2
Notification of Actual Startup	2	1	0	2
Notification of Initial Performance Test	2	1	0	2
Notification of Compliance Status	2	1	0	2
Request for Waiver	0.2	1	0	0.2
Report for Alternative Method/ Monitoring	0.1	1	0	0.1
Report for Performance Test	2	1	0	2
Reports for Periods of Noncompliance	115	2	12	242
			Total (rounded)	254

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Sheet 5: 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)
Computer equipment and GC 1	$32,500	2	$65,000	$5,500	115	$633,000
1 Computer equipment and gas chromatograph (GC) are used to continuously monitor EO emissions to aeration room and back chamber vents							Total	$698,000