Burden Calculation Tables

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Overview

Table 1
Table 2
O&M

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Sheet 1: Table 1

Table 1: Annual Respondent Burden and Cost – NESHAP for Plywood and Composite Products (40 CFR Part 63, Subpart DDDD) (Renewal)
Burden Item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Technical person-hours per occurrence	No. of occurrences per respondent per year	Technical person-hours per respondent per year	Respondents per year a	Technical hours per year (E=CxD)	Management hours per year	Clerical hours per year	Total cost per year ($) b
			(C=AxB)			(F=Ex0.05)	(G=Ex0.10)
1. Applications	N/A									Labor Rates
2. Surveys and studies	N/A									Management	$148.97
3. Reporting requirements										Technical	$119.03
A. Familiarize with regulatory requirements c	1	1	1	244	244	12	24	$32,266.68		Clerical	$57.62
B. Required activities	N/A
C. Create information	See 3E
D. Gather existing information	See 3E
E. Write report
1) Notification of construction /reconstruction d	2	1	2	15	30	2	3	$3,967.22
2) Notification of anticipated startup d	2	1	2	15	30	2	3	$3,967.22
3) Notification of actual startup d	2	1	2	15	30	1.5	3	$3,967.22
4) Notification of applicability of standard d	2	1	2	15	30	2	3	$3,967.22
5) Emissions averaging plan e	120	1	120	0	0	0	0	$0
6) Request for routine control system maintenance exemption f	2	1	2	2	4	0	0	$528.96
7) Notification of initial performance test g	2	1	2	2	4	0	0	$528.96
8) Notification of compliance status
a. With performance test g	80	1	80	2	160	8	16	$21,158.48
b. Without performance test h	60	1	60	0	0	0	0	$0
9) Initial compliance report i
a. No deviations j	2	1	2	2	4	0.2	0.4	$528.96
b. Deviations j	24	1	24	0	0	0	0	$0
c. Startup, shutdown, malfunction report k	8	1	8	0	0	0	0	$0
d. Control system maintenance report l	8	1	8	0	0	0	0	$0
e. Emissions averaging report m	8	1	8	0	0	0	0	$0
10) Semiannual compliance reports i
a. No deviations j	8	2	16	102	1,627	81	163	$215,181.74
b. Deviation j	24	2	48	11	542	27	54	$71,727.25
c. Startup, shutdown, malfunction report k	8	2	16	11	181	9	18	$23,909.08
d. Control system maintenance report l	8	2	16	11	181	9	18	$23,909.08
e. Emissions averaging report m	20	1	20	1	20	1	2	$2,644.81
Subtotal for Reporting Requirements					3,550			$408,253
4. Recordkeeping requirements
A. Familiarize with regulatory requirements c	See 3A
B. Plan activities	N/A
C. Implement activities	N/A
D. Develop record system n	40	1	40	2	80	4	8	$10,579.24
E. Develop startup, shutdown, malfunction plan o	100	1	100	2	200	10	20	$26,448.10
F. Time to enter information
1) Records of startup, shutdown, and malfunction k	1.5	52	78	11.3	881.4	44	88	$116,556.78
2) Records of continuous compliance for PCWP facilities p
a. Record parameters /information	0.25	365	91	114	10,403	520	1040	$1,375,631.80
b. Compile data	24	2	48	114	5,472	274	547	$723,620.02
c. Enter/verify information for semiannual reports	16	2	32	114	3,648	182	365	$482,413.34
3) Records of control system maintenance	See 3E
4) Records of emissions averaging credit/debts	See 3E
G. Calibration of CMS q	16	1	16	114	1,824	91	182	$241,206.67
H. Time to train personnel r	40	1	40	2	80	4	8	$10,579.24
I. Time to refresher training for personnel s	16	1	16	23	368	18	37	$48,664.50
J. Time for audits	N/A
Subtotal for Recordkeeping Requirements					26,399			$3,035,700
Total Labor Burden and Costs (rounded) t					29,900			$3,440,000
Total Capital and O&M Cost (rounded) t								$105,000
Grand Total (rounded) t								$3,550,000
Assumptions:
a The average number of respondents that will be subject to this rule over the next 3 years of this ICR is 244, including 243 existing respondents in years 1-3, plus 2 new respondents projected to become subject to the rule in year 3 for an average of 244 = [243 (yr 1)+ 243 (yr 2) + 245 (yr 3)]/3. There are 113 existing PCWP facilities and 130 existing lumber mills subject to the PCWP NESHAP. During the three-year period of this ICR, an average of 1 new PCWP facility will become subject each year (2/3=1 (rounded)). Therefore, there will be an average of 114 PCWP facilities (113 existing + 1 new = 114). Although subject to the rule, lumber mills are only required to submit an initial notification.
b This ICR uses the following labor rates: $148.97 per hour for managerial labor; $119.03 per hour for technical labor, and $57.62 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 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 This ICR assumes that all respondents will have to familiarize with the regulatory requirements each year.
d One-time activity for new sources projected to commence construction over the 3-year ICR period, including 2 new PCWP mills, 5 new PCWP process lines at existing PCPW mills, and 39 new lumber kilns at existing sawmills, for an average of 15 affected sources per year. [(2 + 5 + 39) /3 = 15]
e The one existing PCWP facility using the emissions averaging compliance option has already written and submitted its emissions averaging plan. New PCWP facilities are not allowed to use emissions averaging.
f We have assumed that each new PCPW mill respondent will submit a request for routine control device maintenance exemption. Note, this is a one-time activity for each respondent. Two new PCWP mills and 5 new process lines are projected over the 3-year ICR period for an average of (2 + 5) / 3 = 2 new PCWP respondents per year.
g We have assumed that each new PCWP facility will comply by conducting performance tests. Two new PCWP mills and 5 new process lines are projected over the 3-year ICR period for an average of (2 + 5) / 3 = 2 new PCWP respondents per year. The notification of compliance status includes the report of the performance tests. Lumber mills are not required to conduct performance tests.
h We have assumed that each new facility will comply by conducting performance test(s). The notification of compliance status includes the report of the performance test(s).
i We have assumed that the respondents’ compliance date is in the first half of the year, so respondents will submit one compliance report (initial compliance report) the first year that they start complying with the rule and two compliance reports (semiannual compliance reports) the following year.
j We have assumed that 90 percent of new and existing PCWP facilities will have no deviations, and 10 percent will have deviations. [0.9 x 2 new PCWP mills = 2] and [0.1 x 2 new PCWP mills = 0] and [0.9 x 113 existing PCWP mills = 102] and [0.1 x 113 existing PCWP mills = 11]
k We have assumed that 10 percent of the PCWP facilities will report an action taken during startup, shutdown, malfunction that are not consistent with the SSMP.
l We have assumed that 10 percent of the PCWP facilities will submit control system maintenance report.
m We have assumed that one existing PCWP facility uses the emissions averaging compliance option. New PCWP facilities are not allowed to use emissions averaging.
n We have assumed that it will take each new PCWP respondent 40 hours to develop a record system for recording parameter monitoring information. [(2 new mills + 5 new process lines) / 3 = 2]
o We have assumed that it will take each new PCWP respondent 80 hours to draft the startup, shutdown, malfunction plan, and another 20 hours to review/revisions, for a total of 100 hours.
p Records of continuous compliance includes, records of CMS data for emission limitations and various records for work practice standards. There are 113 existing PCWP and 2 new PCWP facilities during the three-year period of this ICR [(113 (yr 1)+ 113 (yr 2) + 115 (yr 3))/3 = 114 (rounded)].
q We have assumed that calibration of the CMS will require eight hours per year for each monitor, assuming two CMS per facility for a total of 16 hours per year.
r We have assumed that it will take 40 hours for each new personnel to be trained. [(2 new mills + 5 new process lines) / 3 = 2]
s We have assumed that it will take 16 hours for personnel to complete refresher training and that 20 percent of the existing PCWP facilities will participate [114 x 0.2 = 23].
t 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 Plywood and Composite Products (40 CFR Part 63, Subpart DDDD) (Renewal)
Burden Item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	EPA Hours per Occurrence	Number of Occurrences Per Respondent Per Year	EPA Hours Per Respondent Per Year (C=AxB)	Number of Respondents Per Year a	Technical Hours Per Year (E=CXD)	Management Hours Per Year (F=Ex0.05)	Clerical Hours Per Year (G=Ex0.1)	Total Costs, $ b
1. Attend performance test c	24	1	24	2	48	2.4	4.8	$2,624.33
2. Report review
A. Notification of construction/reconstruction d	2	1	2	15	30	1.5	3	$1,640.21
B. Notification of anticipated startup d	2	1	2	15	30	1.5	3	$1,640.21
C. Notification of actual startup d	2	1	2	15	30	1.5	3	$1,640.21		Labor Rates
D. Notification of applicability of standard (initial notification) d	2	1	2	15	30	1.5	3	$1,640.21		Management	$65.71
E. Review of emissions averaging plan e	40	1	40	0	0	0	0	$0		Technical	$48.75
F. Review of request for routine control system maintenance exemption f	2	1	2	2	4	0.2	0.4	$218.69		Clerical	$26.38
G. Notification of performance test g	1	1	1	2	2	0.1	0.2	$109.35
H. Notification of compliance status
1) With performance test h	8	1	8	2	16	0.8	1.6	$874.78
2) Without performance test i	4	1	4	0	0	0	0	$0
I. Review of initial compliance report j
1) No deviations k	2	1	2	2	4	0.2	0.4	$218.69
2) Deviations k	8	1	8	0	0	0	0	$0
3) Startup, shutdown, malfunction report l	2	1	2	0	0	0	0	$0
4) Control system maintenance report m	2	1	2	0	0	0	0	$0
5) Emissions averaging report e	8	1	8	0	0	0	0	$0
J. Review of semiannual compliance report
1) No deviations k	2	2	4	102	406.8	20.34	40.68	$22,241.18
2) Deviations k	8	2	16	11	180.8	9.04	18.08	$9,884.97
3) Startup, shutdown, malfunction report l	2	2	4	11	45.2	2.26	4.52	$2,471.24
4) Control system maintenance report m	2	2	4	11	45.2	2.26	4.52	$2,471.24
5) Emissions averaging report e	8	2	16	1	16	0.8	1.6	$875
TOTAL ANNUAL BURDEN AND COST(rounded) n					1,020			$48,600
Assumptions:
a The average number of respondents that will be subject to this rule over the next 3 years of this ICR is 244, including 243 existing respondents in years 1-3, plus 2 new respondents projected to become subject to the rule in year 3 for and average of 244 = [243 (yr 1)+ 243 (yr 2) + 245 (yr 3)]/3. There are 113 existing PCWP facilities and 130 existing lumber mills subject to the PCWP NESHAP. During the three-year period of this ICR, an average of 1 new PCWP facility will become subject each year (2/3=1 (rounded)). Therefore, there will be an average of 114 PCWP facilities (113 existing + 1 new = 114). Although subject to the rule, lumber mills are only required to submit an initial notification.
b This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: $65.71 Managerial rate (GS-13, Step 5, $41.07 x 1.6), $48.75 Technical rate (GS-12, Step 1, $30.47 x 1.6), and $26.38 Clerical rate (GS-6, Step 3, $16.49 x 1.6). These rates are from the Office of Personnel Management (OPM) 2018 General Schedule which excludes locality rates of pay.
c We estimate that it will take EPA personnel 24 hours to attend performance tests at new facilities (2 new PCWP mills, 5 new PCWP process lines) required to test during the three-year period of this ICR (7 facilities/3 years = 2).
d One-time activity for new sources projected to commence construction over the 3-year ICR period, including 2 new PCWP mills, 5 new PCWP process lines, and 39 new lumber kilns at existing sawmills, for an average of 15 affected sources per year. [(2 + 5 + 39) /3 = 15]
e We have assumed that one existing PCWP facility uses the emission averaging plan. New facilities are not allowed to use emissions averaging.
f We have assumed that all new facilities will have submitted a request for routine control system maintenance exemption.
g We have assumed that it will take one hour to review the notification of initial performance test.
h We have assumed that all new facilities will conduct an initial performance test(s) and submit a notification of compliance status that includes the report of the performance test(s).
i We have assumed that each new facility will comply by conducting performance test(s). The notification of compliance status includes the report of the performance test(s).
j We have assumed that the facilities compliance date is in the first half of the year, so facilities will submit one compliance report the first year that they start complying with the rule and two compliance reports the years that follow.
k We have assumed that 90 percent of facilities (113 existing PCWP facilities x 0.9 = 102) will have no deviations, and 10 percent (113 x 0.1 = 11) will have deviations
l We have assumed the 10 percent of sources with deviations will report any action taken during a startup, shutdown, or malfunction that are consistent with the SSMP.
m We have assumed the 10 percent of sources with deviations will prepare a control system maintenance report.
n Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: O&M

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 construction/reconstruction	15	1	0	15
Notification of anticipated startup	15	1	0	15
Notification of actual startup	15	1	0	15
Notification of applicability of standard	15	1	0	15
Emissions averaging plan	0	1	0	0
Request for routine control system maintenance exemption	2	1	0	2
Notification of initial performance test	2	1	0	2
Notification of compliance status with performance test	2	1	0	2
Notification of compliance status without performance test	0	1	0	0
Initial compliance report with no deviations	2	1	0	2
Initial compliance report with deviations	0	1	0	0
Initial compliance startup, shutdown, malfunction report	0	1	0	0
Initial compliance control system maintenance report	0	1	0	0
Initial compliance emissions averaging report	0	1	0	0
Semiannual report with no deviations	102	2	0	204
Semiannual report with deviations	11	2	0	22
Semiannual startup, shutdown, malfunction report	11	2	0	22
Semiannual control system maintenance report	11	2	0	22
Semiannual emissions averaging report	1	2	0	2
			Total	340		hours	29,900
						hr/response	88
Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
Year	(A)	(B)	(C)	(D)	(E)
	Number of New Respondents a	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	243	0	0	243
2	0	243	0	0	243
3	7	243	0	5	245
Average	2	243	0	2	244
a New respondents include sources with constructed, reconstructed and modified affected facilities. The 7 new respondents in year 3 consist of 2 new greenfield PCWP facilities and 5 new process lines to be installed at existing PCWP facilities.
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)
Continuous monitoring system a	$2,240	7	$15,680	$84	114	$9,576
Initial tests at new mills (inlet/outlet) b	$60,000	2	$120,000			$0
Initial tests on new process lines at existing mills (inlet/outlet) b	$30,000	5	$150,000			$0
Total c			$286,000			$9,580
Average capital/ startup + O&M cost for 3-year period c, d						$105,000
a Based on average number of PCWP facility respondents over the 3-year period (113 + 113 + (113+2)) / 3 = 114. Annual O&M costs are not currently required in the rule for lumber mills.
b Estimated based on a test cost of $30,000 for each inlet/outlet test for 2 emission points at each facility for a total of $60,000 per facility (except 1 emission point is assumed for new process lines at existing facilities for a testing cost of $30,000).
c Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
d Calculated as the column D total cost divided by 3 years plus the column G total annual cost.
No. of major sources	Existing	Under construction (existing for ICR purposes)	Projected over next 5 years	Projected over 3-year ICR period	Notes
No. PCWP mills	109	4	2	2	2 new OSB mills are projected, assuming 2 RTOs each
PCWP mills also making lumber	16
Projected PCWP lines added at exising mills			7	5	Projected line additions: MDF, PB, LVL, 2 SPW, 2 mills with SW veneer dryers. 7 RTOs projected.
No. sawmills with lumber kilns	121	9
Projected batch kilns added at existing sawmills			25	15
Projected Continuous Drying Kilns added at existing sawmills			40	24
Total	230	13
Data source	ICR	New source projections memo	New source projections memo