Burden Calculations Table

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Overview

# Respondents
# Responses
Respondent Burden
Agency Burden

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Sheet 1: # Respondents

Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
	(A)	(B)	(C)	(D)	(E)
Year	Number of New Respondents	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	23	0	0	23
2	0	23	0	0	23
3	0	23	0	0	23
Average	0	23	0	0	23
1 New respondents include sources with constructed, reconstructed, and modified affected facilities.

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Sheet 2: # Responses

Total Annual Responses
(A) Information Collection Activity	(B) Number of Respondents	(C) Number of Responses	(D) Number of Existing Respondents That Keep Records But Do Not Submit Reports	(E) Total Annual Responses E=(BxC)+D
Notification of applicability	0	0	0	0
Notification of construction/reconstruction	0	0	0	0
Notification of actual startup	0	0	0	0
Initial notification	0	0	0	0
Performance test notification	0	0	0	0
Compliance status notification	0	0	0	0
Performance test reports	0	0	0	0
Startup, shutdown, malfunction reports	0	0	0	0
Semiannual summary report	23	2	0	46
Notification of physical/operational change	2	1	0	2
PRD reporting in semiannual report1	23	0	0	0
			Total	48
1 Annual occurrences of PRD reporting are not counted as separate responses because they are required to be submitted with the semiannual reports.
			hrs/response:	77

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Sheet 3: Respondent Burden

Table 1: Annual Respondent Burden and Cost – NESHAP for Polyether Polyols Production (40 CFR Part 63, Subpart PPP) (Renewal)										Source Type	No.
										Existing	23
				Labor Rates:	$120.27	$141.06	$58.67			New	0
Burden item	A	B	C	D	E	F	G	H
	Person-hours per occurrence	Annual occurrences per respondent	Person-hours per respondent per year (AxB)	Respondents per year a	Technical hours per year (CxD)	Management hours per year (Ex0.05)	Clerical hours per year (Ex0.10)	Annual cost b
1. Applications	N/A
2. Surveys and studies	N/A
3. Reporting requirements
A. Familiarization with Regulatory Requirements	1	1	1	23	23	1.2	2.3	$3,063.37
B. Required activities
i. Initial performance test: process vents	N/A
ii. Initial performance test: wastewater	N/A
C. Write reports
i. Notification of applicability	N/A
ii. Notification of construction/reconstruction	N/A
iii. Notification of actual startup	N/A
iv. Initial notification	N/A
v. Performance test notification	N/A
vi. Compliance status notification	N/A
vii. Performance test report	N/A
viii. Malfunction report	2	1	2	0	0	0	0	$0
ix. Semiannual summary report	20	2	40	23	920	46	92	$122,534.80
x. Notification of physical/operational changec	2	1	2	2	4	0.2	0.4	$532.76
xi. PRD reporting in semiannual report	5.5	2	11	23	253	12.65	25.3	$33,697.07
Subtotal for Reporting Requirements					1,380			$159,828
4. Recordkeeping requirements
A. Familiarization with Regulatory Requirements	N/A
B. Develop record system	N/A
C. Time to train personnel	N/A
D. Continuously monitor parameters	See 3C
E. LDAR program	88	1	88	23	2,024	101.2	202.4	$269,576.56
F. Startup, shutdown, malfunction plan	N/A
Subtotal for Recordkeeping Requirements					2,327			$269,577
TOTAL ANNUAL BURDEN AND COST (Rounded)					3,710			$429,000
Capital and O&M Costs (See Section 6(b)(iii))								$0
TOTAL COST					3,710			$429,000
Assumptions:
a EPA estimates an average of 23 existing sources will be subject to the NESHAP over the next 3 years. No new sources are expected to become subject over the three-year ICR period.
b This ICR uses the following labor rates: $120.27 (technical), $141.06 (managerial), and $58.67 (clerical). 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.” They have been increased by 110 percent to account for the benefit packages available to those employed by private industry.
c EPA assumes 10% of existing sources will submit notifications of physical/operational change (23 x 10% = 2.3, or 2 after rounding).
d Totals are rounded to three significant figures. Figures may not add exactly due to rounding.

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Sheet 4: Agency Burden

Table 2: Average Annual Burden and Cost – NESHAP for Polyether Polyols Production (40 CFR Part 63, Subpart PPP) (Renewal)
				Labor Rates:	$49.44	$66.62	$26.75
Burden item	A	B	C	D	E	F	G	H
	EPA person-hours per occurrence	Annual occurrences per respondent	EPA person-hours per respondent per year (AxB)	Respondents per year a	Technical hours per year (CxD)	Management hours per year (Ex0.05)	Clerical hours per year (Ex0.10)	Annual costb		ERG Notes
Review notification of construction/reconstruction	2	1	2	0	0	0	0	$0
Review notification of actual startup	2	1	2	0	0	0	0	$0
Review initial notification report	8	1	8	0	0	0	0	$0
Review notification of performance test	4	1	4	0	0	0	0	$0
Review notification of compliance status	10	1	10	0	0	0	0	$0
Review performance test results	10	1	10	0	0	0	0	$0
Malfunction report	2	1	2	0	0	0	0	$0
Review semiannual summary reports	2	2	4	23	92	4.6	9.2	$5,101.03
Review notification of physical/operational change	2	1	2	2	4	0.2	0.4	$221.78
TOTAL ANNUAL BURDEN AND COST (ROUNDED)					110			$5,320
Assumptions:
a EPA estimates an average of 23 existing sources will be subject to the NESHAP over the next 3 years. No new sources are expected to become subject over the three-year ICR period.
b This ICR uses the following labor rates: $49.44 (technical), $66.62 (managerial), and $26.75 (clerical). 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 Totals are rounded to three significant figures. Figures may not add exactly due to rounding.