Burden Calculation Tables

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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 Hydrochloric Acid Production (40 CFR Part 63, Subpart NNNNN) (Amendments)
					117.92	147.4	57.02
Burden item	(A) Person-hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person-hours per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical Person-hours per year (E=CxD)	(F) Management person-hours per year (Ex0.05)	(G) Clerical person-hours per year (Ex0.1)	(H) Cost, $ b
1. Applications	N/A
2. Survey and Studies	N/A
3. Reporting Requirements
A. Familiarize with rule requirements c	4	1	4	19	76	3.8	7.6	$9,955.39
B. Gather information c	4	1	4	0	0	0	0	$0.00
C. Write reports
Initial notification c	2	1	2	0	0	0	0	$0.00
Application for construction c	2	1	2	0	0	0	0	$0.00
Notification of intent to conduct performance test	2	1	2	3.8	7.6	0.38	0.76	$995.54
Notification of compliance status c	19.5	1	19.5	0	0	0	0	$0.00
First compliance report c, d	8.5	1	8.5	0	0	0	0	$0.00
Semiannual compliance report e	4.5	2	9	19	171	8.55	17.1	$22,399.63
Subsequent performance test reports f	4	1	4	0	0	0	0	$0.00
Startup, shutdown, malfunction report g	2	10	20	0	0	0	0	$0.00
Subtotal for Reporting Requirements					293			$33,351
4. Recordkeeping Requirements
A. Plan activities c, h	10	1	10	0	0	0	0	$0.00
B. Implement activities
Record startups, shutdown, malfunctions i	1	10	10	19	190	9.5	19	$24,888.48
Conduct performance test	48.5	1	48.5	3.8	184.3	9.22	18.43	$24,141.83
Record CPMS measurements j	1	365	365	19	6,935	346.75	693.5	$908,429.52
CMPS calibration and maintenance k	3.9	50	195	19	3,705	185.25	370.5	$485,325.36
Check for and repair leaks l	1	365	365	19	6,935	346.75	693.5	$908,429.52
C. Develop record system
Startup, shutdown, malfunction plan c	40	1	40	0	0	0	0	$0.00
Site-specific monitoring plan c	20	1	20	0	0	0	0	$0.00
Site-specific test plan c	20	1	20	0	0	0	0	$0.00
Leak detection and repair plan c	40	1	40	0	0	0	0	$0.00
Record maintenance activities o	1	4	4	19	76	3.8	7.6	$9,955.39
D. Time to train personnel			0			0	0	$0.00
CPMS acquisition and installation c	20	1	20	0	0	0	0	$0.00
CPMS inspection and monitoring c	4	1	4	0	0	0	0	$0.00
E. Store, file, and maintain records m	20	1	20	19	380	19	38	$49,776.96
F. Retrieve records/reports n	20	1	20	19	380	19	38	$49,776.96
Subtotal for Recordkeeping Requirements					21,603			$2,460,724
TOTAL LABOR BURDEN AND COST (rounded)					22,000			$2,500,000
Capital and O&M Costp								$162,000
Grand TOTALp								$2,700,000
Assumptions:
a We have assumed that the average number of respondents that will be subject to the rule will be 19. There will be no additional new sources that
will become subject to the rule over the three-year period of this ICR.
b This ICR uses the following labor rates: $147.40 per hour for Executive, Administrative, and Managerial labor; $117.92 per hour for Technical labor, and
$57.02 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 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 This is a one-time only activity for each facility and only sources that started up prior to April 17, 2003 are required to submit initial notification
d We have assumed that no new respondents will prepare the first compliance report.
e We have assumed that it will take each respondent 4.5 hours two times per-year to prepare the semiannual compliance report.
f We have assumed that no facilities will take 4 hours to perform tests after the initial compliance determination , by either bringing a new product on line or
by significantly increasing its production.
g We have assumed that it will take each new respondents two hours ten times a year to prepare a SSM report.
h We have assumed that it will take each respondent 10 hours to record plan activities.
i We have assumed that each respondent will have to implement SSM activities 10 times per-year.
j We have assumed that respondents will have to record CPMS measurements 365 time per year.
k We have assumed that respondents will have to implement CPMS calibration and maintenance activities 50 times per year.
l We have assumed that respondents are required to check for and repair leaks 365 times per-year.
m We have assumed that each respondent will take 20 hours once per-year to store, file and maintain records.
n We have assumed that it will take respondent 20 hours to retrieve records/reports once per-year.
o We have assumed respondants will average 4 maintenance activites per year based on comments submitted by industry. See EPA-HQ-OAR-2018-0417-0134 at pages 19-20.
p Totals have been rounded to 3 significant figures. Figures may not round exactly due to rounding.

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Sheet 2: Table 2

Table 2: Average Annual EPA Burden and Cost – NESHAP for Hydrochloric Acid Production (40 CFR Part 63, Subpart NNNNN) (Amendments)
					48.75	65.71	26.38
Activity	(A) Person-hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person-hours per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical Person-hours per year (E=CxD)	(F) Management person-hours per year (Ex0.05)	(G) Clerical person-hours per year (Ex0.1)	(H) Cost, $ b
Review initial notification c	4	1	4	0	0	0	0	$0
Review application for construction c	4	1	4	0	0	0	0	$0
Review notification of intent to conduct test d	4	1	4	0	0	0	0	$0
Review notification of compliance status c	20	1	20	0	0	0	0	$0
Review first compliance report e	20	1	20	0	0	0	0	$0
Review semiannual compliance report e	20	2	40	19	760	38	76	$41,551.86
Review subsequent performance test report f	10	1	10	0	0	0	0	$0
Review startup, shutdown, malfunction report g	8	10	80	0	0	0	0	$0
Attend performance test	20	1	20	0	0	0	0	$0
TOTAL ANNUAL BURDEN AND COST (rounded) h					874			$41,600
Assumptions:
a We have assumed that the average number of respondents that will be subject to the rule will be 19. There will be two additional new sources per year that
will become subject to the rule over the three-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 x 1.6), Technical rate of $48.75 (GS-12, Step 1, $30.47 x 1.6), and Clerical rate of $26.38 (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 This is a one-time only activity for each facility and only sources that started up prior to April 17, 2003 are required to submit initial notification.
d We have assumed that each respondent will take 4 hours to review notification of intent to conduct test.
e We have assumed that each respondent will take 20 hours to review the first compliance report (applies only to new respondents) once per year and 20 hours to review the semiannual compliance report twice per year.
f We have assumed that no facilities will perform tests after the initial compliance determination.
g We have assumed that it will take each new respondents eight hours to review the SSM report.
h 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)
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 systems (CMS)	$712	2	$1,424	$8,473	19 (existing)	$160,987
	N/A	N/A	N/A	$16,385	0 (new)	$0
Total			$1,420			$161,000