Burden Calculation Tables

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Overview

Table 1
Table 2
Word Count

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Sheet 1: Table 1

Table 1: Average Annual Respondent Burden and Cost – NESHAP for Cellulose Products Manufacturing (40 CFR Part 63, Subpart UUUU) (Proposed Amendments)
					$119.47	$139.63	$58.15	Labor Cost Per Hour
Burden item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Person hours per occurrence	No. of occurrences per respondent per year	Person hours per respondent per year (C=AxB)	Respondents per year a	Technical person- hours per year (E=CxD)	Management person hours per year (F=Ex0.05)	Clerical person hours per year (G=Ex0.1)	Total Cost per year b
1. Applications	N/A
2. Survey and Studies	N/A
3. Reporting Requirements
A. Familiarize with regulatory requirements c	8	1	8	2.7	21	1.1	2.1	$2,822
B. Required activities d
Prepare for periodic performance test	24	1	24	2	48	2.4	4.8	$6,349
Attend periodic performance test	24	2	48	2	96	4.8	9.6	$12,697
C. Create information	See 3B
D. Gather existing information	See 3B
E. Write report														No. of responses
Notification of construction/reconstruction e,f	2	1	2	0	0	0	0	$0						0
Notification of actual startup e,f	2	1	2	0	0	0	0	$0						0
Notification of applicability e,f	2	1	2	0	0	0	0	$0						0
Notification of performance test f,g	2	1	2	2	4	0.2	0.4	$529						2
Notification of CMS performance evaluation f,g	2	1	2	2	4	0.2	0.4	$529						2
Notifications for equipment leaks e,f	2	1	2	0	0	0	0	$0						0
Notifications for wastewater e,f	2	1	2	0	0	0	0	$0						0
Notification of compliance status g,h	40	1	40	2.7	107	5.3	11	$14,108						2.7
Semiannual report - no deviations i	8	2	16	6.4	102	5.1	10	$13,544						12.8
Semiannual report - deviations j	16	2	32	1.6	51	2.6	5.1	$6,772						3.2
Semiannual report - equipment leaks k	303	2	606	3	1,818	91	182	$240,458						6
Semiannual report - wastewater	See 4E													6
Semiannual report - other l	8	2	16	8	128	6.4	13	$16,930						16
Subtotal for Reporting Requirements					2,737			$314,739						51
4. Recordkeeping requirements
A. Familiarize with regulatory requirements	See 3A
B. Plan activities	N/A
C. Implement activities	N/A
D. Develop record system	N/A
E. Time to enter information
Records of failures to meet standards/actions taken to minimize emissions m	2	12	24	0.4	10	0.5	1.0	$1,270
Records of CMS data n	1	365	365	8	2,920	146	292	$386,215
Records of closed-loop systems o	2	2	4	1	4	0.2	0.4	$529
Records of nitrogen systems p	2	2	4	5	20	1	2	$2,645
Records of material balances q	8	2	16	5	80	4	8	$10,581
Records of supporting calculations r	8	2	16	8	128	6.4	13	$16,930
Records for equipment leaks	See 3E
All other records	See 3E
F. Time to train personnel
Initial training e,s	40	1	40	0	0	0	0	$0
Refresher training t	16	1	16	8	128	6.4	13	$16,930
G. Time to transmit or disclose information u
Compile data	24	2	48	8	384	19	38	$50,790
Enter and verify information for semiannual report	16	2	32	8	256	13	26	$33,860
H. Time for audits	N/A
Subtotal for Recordkeeping Requirements					4,519			$519,750						Hours per response
TOTAL LABOR BURDEN AND COST					7,256			$834,489						143
TOTAL ANNUALIZED CAPITAL AND O&M COST								$119,511
GRAND TOTAL								$954,000
Assumptions:
a We estimate that there are 8 sources that are subject to the standard which includes the following facilities: 3 cellulose ether; 1 cellulosic sponge; 3 cellulose food casing; and 1 cellophane (for a total of 8 respondents). We estimate no new sources will become subject to the rule each year over the 3-year period of this ICR.
b This ICR uses the following labor rates: $139.63 per hour for Managerial labor; $119.47 per hour for Technical labor, and $58.15 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, December 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% to account for the benefit packages available to those employed by private industry.
c We have assumed that it will take the respondents 8 hours to familiarize themselves with the regulatory requirements in the first year after publication of RTR amendments (8 respondents/3 years = 2.7).
d We estimate that it will take the respondent 24 hours to prepare for periodic performance test (e.g., prepare test plan) and 24 hours to attend the test. We also estimate 2 plant personnel will attend the test.
e These requirements are one-time requirements that apply to new respondents. There are no new respondents estimated over the 3-year period of this ICR.
f We estimate that it will take the respondent 2 hours to complete the notification.
g We estimate that 6 facilities will need to submit notification of performance test, conduct the test, and report the results through CEDRI. No performance test required for the 2 cellulosic sponge and cellophane facilities because these facilities use recovery devices to meet the emission limit. These facilities are required to conduct a compliance demonstration based on the material balance for their process. The periodic testing will occur once during the 3-year ICR period (6 respondents/3 years = 2). All 8 facilities must submit a notification of compliance status with results of the performance test (8 respondents/3 years = 2.7).
h We estimate that it will take each respondent 40 hours to prepare the notification of compliance status.
i We have assumed that 80% of all respondents will report no deviation (0.8 x 8 respondents = 6.4).
j We have assumed that 20% of all respondents will report a deviation (0.2 x 8 respondents = 1.6).
k We estimate that it will take each respondent 303 hours on a semiannual basis to write reports for 3 cellulose ether facilities subject to leak detection and repair (LDAR) requirements.
l All other reports, including changes of information, closed-vent systems, bypass lines, heat exchanger systems, and storage vessel control device maintenance, will be reported twice per year for all 8 facilities.
m We have assumed that 5% of respondents will fail to meet standards each year (0.05 x 8 = 0.4). We estimate that each respondent will take 2 hours 12 times per year to keep records of failures to meet the standards and the actions taken to minimize emissions..
n We estimate that it will take each respondent 1 hour to record information on a daily basis on process vent, storage tank and wastewater monitoring and inspections.
o We estimate that it will take each respondent 2 hours to enter information on 1 cellulose ether facility with a closed-loop system.
p We estimate that it will take each respondent 2 hours to enter information on 5 viscose process facilities with CS2, unloading and storage operations.
q We estimate that it will take each respondent 8 hours to enter information on 5 viscose process facilities using material balances.
r We estimate that it will take each respondent 8 hours to enter information on supporting calculations twice per year.
s We estimate that it will take each respondent 1 week (40 hours) to provide initial training to personnel with new sources.
t We estimate that it will take each respondent 2 days (16 hours) to provide refresher training to personnel.
u We have assumed that each respondent will enter and verify information for the semiannual report twice per year.

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Sheet 2: Table 2

Table 2: Average Annual EPA Burden and Cost – NESHAP for Cellulose Products Manufacturing (40 CFR Part 63, Subpart UUUU) (Proposed Amendments)
					$48.75	$65.71	$26.38	Labor Cost per Hour
Activity	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	EPA person-hours per occurrence	No. of occurrences per plant per year	EPA person hours per plant per year (C=AxB)	Plants per year a	Technical person-hours per year (E=CxD)	Management person-hours per year (F=Ex0.05)	Clerical person-hours per year (G=Ex0.1)	Cost, $ b
Activity
Attend performance test c	24	1	24	0.2	4.8	0.2	0.5	$262
Excess emissions enforcement activities d	120	1	120	0.06	7.2	0.4	0.7	$394
Review reports
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 applicability e	2	1	2	0	0	0	0	$0
Notification of performance test f	2	1	2	2	4	0.2	0.4	$219
Notification of CMS performance evaluation f	2	1	2	2	4	0.2	0.4	$219
Notification of compliance status g	4	1	4	2.7	11	0.5	1.1	$583
Report of performance test h	8	1	8	2	16	0.8	1.6	$875
Report of CMS performance evaluation h	8	1	8	2	16	0.8	1.6	$875
Semiannual report - no deviations i	2	2	4	6.4	26	1.3	2.6	$1,400
Semiannual report - deviations j	8	2	16	1.6	26	1.3	2.6	$1,400
Semiannual report - equipment leaks k	8	2	16	3	48	2.4	4.8	$2,624
Semiannual report - wastewater k	8	2	16	3	48	2.4	4.8	$2,624
Semiannual report - other l	2	2	4	8	32	1.6	3.2	$1,750
TOTAL ANNUAL BURDEN AND COST					278			$13,224
Assumptions:
a We estimate that there are 8 sources that are subject to the standard which includes the following facilities: 3 cellulose ether; 1 cellulosic sponge; 3 cellulose food casing; and 1 cellophane (for a total of 8 respondents). We estimate no new sources will become subject to the rule each year over the 3-year period of this ICR.
b This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: Managerial rate of $65.71 (GS-13, Step 5, $41.07 + 60%), Technical rate of $48.75 (GS-12, Step 1, $30.47 + 60%), and Clerical rate of $26.38 (GS-6, Step 3, $16.49 + 60%). These rates are from the Office of Personnel Management (OPM) “2019 General Schedule” which excludes locality rates of pay.
c We estimate that it will take EPA personnel 24 hours to attend performance tests at 10% of facilities required to test (0.1 x 6 respondents/3 years = 0.2).
d We estimate that 10% of the affected facilities will be required to retest as a result of deviations, and EPA personnel will attend 10% of these tests (0.1 x 0.1 x 6 respondents = 0.06).
e We estimate that it will take EPA personnel 2 hours to complete review of the initial notifications (construction/reconstruction, actual startup, applicability of standard).
f We estimate that it will take EPA personnel 2 hours to complete review of the notifications of performance test and CMS performance evaluation for facilities required to test (6 respondents/3 years = 2).
g We estimate that it will take EPA personnel 4 hours to complete review of the notification of compliance status for all 8 facilities (8 respondents/3 years = 2.7).
h We estimate that it will take EPA personnel 8 hours to complete review of the performance test and CMS performance evaluation data for facilities required to test (6 respondents/3 years = 2).
i We have assumed that 80% of respondents will report no deviations (0.8 x 8 respondents = 6.4) and that it will take EPA personnel 2 hours two times per year to review those reports.
j We have assumed that 20% of respondents will report deviations (0.2 x 8 respondents = 1.6) and that it will take EPA personnel 8 hours two times per year to review those reports.
k We estimate that it will take EPA personnel 8 hours two times per year to review the reports of 3 cellulose ether facilities subject to LDAR and wastewater requirements.
l We estimate that it will take EPA personnel 2 hours two times per year to review all other reports, including changes of information, closed-vent systems, bypass lines, heat exchanger systems, and storage vessel control device maintenance, for all 8 facilities.

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Sheet 3: Word Count

	Word Count
Preamble	28,103
Amendatory	14,941
Total	43,044
	Read/understand rule
	43,044	words in FR package
	100	words/min reading rate
	430	min to read pkge
	7	hrs to read pkge		bumped up to 8