Burden Calculations

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Overview

Table 1
Table 2
Capital and O&M

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Sheet 1: Table 1

Table 1: Annual Respondent Burden and Cost – NESHAP for Group IV Polymers and Resins (40 CFR Part 63, Subpart JJJ) (Renewal)
Burden Item	(A) Person-hours per occurrence	(B) Number of occurrences per year	(C) Person-hours per respondent (C=AxB)	(D) Respondents per year a	(E) Technical person-hours (E=CxD)	(F) Management person-hours (F=Ex0.05)	(G) Clerical person-hours (G=Ex0.1)	(H) Total Cost b ($)
1. Applications	N/A									Labor Rates
2. Survey and Studies	N/A									Management	$141.06
3. Acquisition, Installation, & Utilization of Tech. & Systems	N/A									Technical	$120.27
4. Reporting Requirements										Clerical	$58.67
A. Familiarize with regulatory requirements c	40	1	40	24	960	48	96	$127,862.40
B. Required activities d	6.08	13	79	27	2,134	107	213	$284,238.12
C. Create information d	17.85	99	1,767	27	47,713	2,386	4,771	$6,354,901.13
D. Gather existing information d	2.5	677	1,693	27	45,698	2,285	4,570	$6,086,450.03
E. Write report								$0
Notification of compliance status	20	1	20	0	0	0	0	$0
Notification of storage vessel inspection e	5	6	30	24	720	36	72	$95,896.80
Notification of performance tests	10	1	10	0	0	0	0	$0
Notification of alternative test method f	5	1	5	0	0	0	0	$0
Notification of special compliance requirements g	5	1	5	0	0	0	0	$0
Report of newly constructed/reconstructed source	2	1	2	0	0	0	0	$0
Operating permit application	40	1	40	0	0	0	0	$0
Precompliance report h	40	1	40	0	0	0	0	$0
Progress reports for affected sources receiving an extension of compliance i	4	2	8	0	0	0	0	$0
Emissions averaging plans j	120	1	120	0	0	0	0	$0
Request for approval for a nominal control efficiency for use in calculating credits for emission averaging j	2	1	2	0	0	0	0	$0
Updates to emissions averaging plan k	20	1	20	1	20	1	2	$2,663.80
Semiannual periodic reports l	80	2	160	23	3,680	184	368	$490,139.20
Quarterly periodic reports for facilities using emission averaging and where a respondent did not qualify for semiannual reporting l	80	4	320	4	1,280	64	128	$170,483.20
Semiannual periodic reports (PRD monitoring)	5.5	2	11	27	297	15	30	$39,557.43
Semiannual periodic reports (Equip. leaks)	3	2	6	1	6	0.3	0.6	$799.14
Semiannual periodic reports (PCCT)	1	2	2	1	2	0.1	0.2	$266.38
Report of changes to the primary product for a TPPU or process unit m	2	1	2	3	6	0.3	0.6	$799.14
Report for batch process vents n	2	1	2	3	6	0.3	0.6	$799.14
Report for PET sources using a dimethyl terephthalate process o	2	1	2	2	4	0.2	0.4	$532.76
Malfunction Reports p	8	1	8	3	24	1.2	2.4	$3,196.56
Affirmative defense	30	-	-	0	0	0	0	$0
Subtotal for Reporting Requirements					117,932			$13,658,585
5. Recordkeeping Requirements
A. Familiarize with regulatory requirements	See 4A
B. Plan activities d	See 4B
C. Implement activities d	See 4B
D. Develop record system	40	1	40	0	0	0	0	$0
E. Time to enter information d
Plan Activities	See 4B
Create, Test, Research, Develop	See 4C
Gather information, Monitor, Inspect	See 4D
Process, Compile, Review	20	1	20	27	540	27	54	$71,922.60
F. Time to train personnel d	5.25	4	21	27	567	28	57	$75,518.73
G. Time to Record and disclose information d	17.46	26	454	27	12,258	613	1,226	$1,632,643.02
H. Store, file and maintain records d	6.77	35	237	27	6,399	320	640	$852,282.81
I. Time for audits	N/A
Subtotal for Recordkeeping Requirements					22,729			$2,632,367		responses	hr/response
TOTAL LABOR BURDEN AND COST (rounded) q					141,000			$16,300,000		218	647
TOTAL CAPITAL AND O&M COST (rounded) q								$7,430,000
GRAND TOTAL (rounded) q								$23,700,000
Assumptions:
a We assume there are an average of 27 sources (TPPUs) at 24 facilities subject to the rule and no additional sources per year will become subject to the rule during 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 This ICR assumes all existing sources will have to familiarize with the regulatory requirements each year.
d Since the activities within each burden category (i.e., process vents, equipment leaks, wastewater, heat exchangers, and equipment leaks) can vary significantly, it is too inaccurate to assume an average activity time (Column A) to calculate hours per facility (Column C). Therefore, we estimated the total hours per facility and the number activities per year (Column B) to back-calculate the person-hrs per occurrence value in Column A. The burden for these activities are based on the approach used in the HON (Subparts F, G, H, and I). Since so much variability exists, it is important to note that this is an estimate and is only used to back-calculate Column A.
e This ICR assumes that each facility will refill storage vessels that have been emptied and degassed 6 times per year.
f This ICR assumes that 5% of new sources will use alternative test methods.
g This ICR assumes that 5% of new sources will use special compliance requirements.
h This ICR assumes that 10% of new sources will have to submit precompliance reports.
i This ICR assumes that all existing sources are already in compliance; new sources cannot receive compliance extensions.
j This ICR assumes 10% of existing facilities will elect to use emission averaging and that all existing respondents were expected to be in compliance as of the 2014 final rule. New facilities cannot use emissions averaging. This ICR also assumes no existing facilities will elect to use nominal control after submitting the initial emissions averaging plan.
k This ICR assumes 1 facility per year using an emissions averaging plan will make changes requiring an update to the emissions averaging plan.
l This ICR assumes that 5% of the 27 sources (TPPUs) will not qualify for semiannual reports and will be required to submit quarterly reports. (27 TPPUs x 0.05 = 1.35) In addition, 10% of the 24 facilities using emissions averaging are required to submit quarterly reports. (24 respondents x (0.10) = 2.4). Therefore we estimate quarterly reports will be submitted for 4 sources. (1.35 + 2.4 = 3.75, rounded to 4) The remaining 23 sources will all submit semiannual reports.									<- Changed these from 34 to 27, and from 31 to 24.
m This ICR assumes that 10% of sources will have changes to their primary product. (27 sources x 0.10 = 2.7, rounded to 3)									<- Changed these from 34 to 27
n This ICR assumes that 10% of sources will makes changes to batch process vents. (27 sources x 0.10 = 2.7, rounded to 3)									<- Changed these from 34 to 27
o This ICR assumes that 10% of PET sources will make changes to a dimethyl terephthalate process. There is a total of 15 PET facilities subject to the rule. (15 facilities x 1.1 sources/facility x 10% = 1.65 sources, rounded to 2)
p This ICR assumes that 10% of sources will have to submit malfunction reports. (27 sources x 0.10 = 2.7, rounded to 3)									<- Changed these from 34 to 27
q 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 – NESHAP for Group IV Polymers and Resins (40 CFR Part 63, Subpart JJJ) (Renewal)
Activity	(A) EPA person-hours per occurrence	(B) Number of occurrences per year	(C) EPA Person-hours per plant (C=AxB)	(D) Plants per year a	(E) Technical person-hours (E=CxD)	(F) Management person-hours (F=Ex0.05)	(G) Clerical person-hours (G=Ex0.1)	(H) Total Cost b ($)
Activity										Labor Rates
1. Performance Tests: Initial	40	1	40	0	0	0	0	$0		Management	$66.62
2. Performance Tests: Repeat c	40	1	40	0	0	0	0	$0		Technical	$49.44
Reports Review:										Clerical	$26.75
1. Initial d	2	1	2	0	0	0	0	$0
2. Implementation plan, pre-compliance report or permit d	20	1	20	0	0	0	0	$0
3. Compliance status d	40	1	40	0	0	0	0	$0
4. Review equipment leak monitoring d	7	1	7	27	189	9	19	$10,479.29
5. Report of construction/reconstruction d	2	1	2	0	0	0	0	$0
6. Notification of performance test d	2	1	2	0	0	0	0	$0
7. Notification of storage vessel inspection e	2	6	12	24	288	14	29	$15,968.45
8. Review updates to emission averaging plan f	5	1	5	1	5	0.25	0.5	$277.23
9. Review report of changes to the primary product for a TPPU or process unit g	2	1	2	3	6	0.3	0.6	$332.68
10. Review report for batch process vents h	2	1	2	3	6	0.3	0.6	$332.68
11. Review report for PET sources using dimethyl terephthalate process i	2	1	2	2	4	0.2	0.4	$221.78
12. Review of test results d	8	1	8	0	0	0	0	$0
13. Review malfunction reports j	2	1	2	3	6	0.3	0.6	$332.68
14. Review semiannual periodic reports d, k	3	2	6	23	138	6.9	14	$7,651.55
15. Review of quarterly periodic reports d, k	4	4	16	4	64	3	6	$3,548.54
TOTAL (rounded) e					810			$39,100
Assumptions:
a We assume there are an average of 27 sources at 24 facilities subject to the rule and no additional sources per year will become subject to the rule during 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 This ICR assumes 20% of sources will have to repeat performance tests.
d The burden for these activities are based on similar requirements in the HON (Subparts F, G, H, and I). The HON describes these activities as follows:
1. Initial represents the EPA review of all initial reports received.
2. Implementation plan or permit represents the EPA review of all implementation plans, or permit applications if submitted in lieu of an implementation plan.
3. Compliance status represents compliance status verification by the EPA for the portions of the standard which a source must comply with before the compliance date.
4. Review equipment leak monitoring represents the review and screening of periodic reports received as a result of the equipment leaks standard.
5. Report of construction/reconstruction represents the EPA review of this notification from new sources.
6. Notification of performance test represents the EPA review of this notification from new sources.
7. Review of test results represents the EPA review of performance test results for new sources.
8. Review periodic reports represents the EPA review of periodic reports.
e This ICR assumes that each facility will refill storage vessels that have been emptied and degassed 6 times per year.
f This ICR assumes 1 facility per year using an emissions averaging plan will make changes requiring an update to the emissions averaging plan. This activity may also include review of front-end or back-end operations limits.
g This ICR assumes that 10% of sources will have changes to their primary product.
h This ICR assumes that 10% of sources will makes changes to batch process vents.
i This ICR assumes that 10% of PET sources will make changes to a dimethyl terephthalate process. There is a total of 15 PET facilities subject to the rule. (15 facilities x 1.1 sources/facility x 10% = 1.65 sources, rounded to 2)
j This ICR assumes that 10% of sources will have to submit malfunction reports.
k This ICR assumes that 5% of the 27 sources (TPPUs) will not qualify for semiannual reports and will be required to submit quarterly reports. (27 TPPUs x 0.05 = 1.35) In addition, 10% of the 24 facilities using emissions averaging are required to submit quarterly reports. (24 respondents x (0.10) = 2.4). Therefore we estimate quarterly reports will be submitted for 4 sources. (1.35 + 2.4 = 3.75, rounded to 4) The remaining 23 sources will all submit semiannual reports.
l Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: Capital and O&M

Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A)	(B)	(C)	(D)	(E)	(F)	(G)
Burden	Capital/Startup Cost for One Respondent	Number of New Respondents	Total Capital/Startup Cost, (B X C)	Annual O&M Costs for One Respondent a	Number of Respondents with O&M	Total O&M, (ExF)
Electronic indicators for PRD a	$15,930	0	$0	$0	0	$0
Monitoring equipment for process vents and wastewater b	$25,000	0	$0	$275,000	27	$7,425,000
Monitoring equipment for equipment leaks b	$1,400	0	$0	$0	0	$0
Total (rounded) c			$0			$7,430,000		$7,430,000
a Based on costs from the 2014 final rule, the total capital cost for the electronic indicators for PRDs across all facilities is estimated to be $3,814,120 (see ICR No. 2457.02). This cost has been annualized by multiplying the capital recovery factor by the capital cost. The capital recovery factor is based on an interest rate of 7 percent and an assumed equipment life of 10 years. (Capital cost per monitoring system = $3,814,120 x 0.142 / 34 monitoring system = $15,930/monitoring system. The operation and maintenance (O&M) costs expected from operating the electronic indicators is assumed to be minimal.
b Capital and O&M costs for process vents, wastewater, and equipment leaks are based on estimates for similar requirements in the HON (Subparts F, G, H and I). The HON uses the following assumptions:
1. Subpart G
-Total Capital/Startup Cost of Monitoring Equipment: The cost to purchase monitoring equipment is approximately $20-30K for process vents and wastewater operations, or an average of $25K with a 10-year life expectancy and a 7 percent depreciation rate, or $2,225 per year. There are no associated costs for transfer racks and storage tanks. Only new sources need to buy monitoring equipment.
-Total Cost of Operation and Maintenance of Monitoring Equipment: The cost to industry associated with the operation and maintenance (O&M) is approximately $100-500K per year (capital/startup depreciation not included) for reactor process vents and wastewater operations. The cost associated with the operation and maintenance is $50-100K per year (capital/startup depreciation not included) for distillation unit process vents. There are no associated costs for transfer racks and storage tanks. The average O&M cost is assumed to be the average of the two ranges, or $275,000 per year. Operation and maintenance incur for both new and existing sources.
2. Subpart H
-Total Capital/Startup Cost of Monitoring Equipment: Only new sources will buy an organic volatile analyzer. Estimate the average cost of a monitor is $7,000 with a 5-year expected life. The equipment is not capitalized, so no discount rate applies. The average annual cost is, therefore, $7,000/5, or $1,400/yr.
-Total Cost of Operation and Maintenance of Monitoring Equipment: The operation of the monitors is included in the monitoring equipment costs. Maintenance costs on these units is incidental; therefore, no maintenance or operation costs are incurred.
3. The HON does not estimate any capital or O&M costs for Subparts F and I.
c Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
	Number of Respondents
		Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
		(A)	(B)	(C)	(D)	(E)
	Year	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	24	0	0	24
	2	0	24	0	0	24
	3	0	24	0	0	24
	Average	0	24	0	0	24
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 compliance status	0	1	0	0
Notification of storage vessel inspection	24	6	0	144
Notification of performance tests	0	1	0	0
Notification of alternative test method	0	1	0	0
Notification of special compliance requirements	0	1	0	0
Pre-compliance report	0	1	0	0
Progress reports for affected sources receiving an extension of compliance	0	2	0	0
Emissions averaging plans	0	1	0	0
Request for approval for a nominal control efficiency for use in calculating credits for emission averaging	0	1	0	0
Updates to emissions averaging plan	1	1	0	1
Report of changes to the primary product for a TPPU or process unit	3	1	0	3
Report of newly constructed/reconstructed source	0	1	0	0
Operating permit application	0	1	0	0
Report for batch process vents	3	1	0	3
Report for PET sources using a dimethyl terephthalate process	2	1	0	2
Malfunction Reports	3	1	0	3
Semiannual reports a	23	2	0	46
Quarterly periodic reports for facilities using emission averaging and where a respondent did not qualify for semiannual reporting	4	4	0	16
Total (rounded) b				218
a There are 27 affected sources (PRD) monitored at 24 facilities. For the 23 sources qualifying for semiannual reports, this information will be included in the required periodic report and is not considered a separate response. For the 4 sources required to submit quarterly reports, we assume this information will be submitted quarterly as a separate report.
b Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.