Burden Calculation Tables

2046t10.xlsx

NESHAP for Mercury Cell Chlor-Alkali Plants (40 CFR part 63, subpart IIIII) (Proposed Rule)

Burden Calculation Tables

OMB: 2060-0542

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Overview

Table 1a-Yr1
Table 1b-Yr2
Table 1c-Yr3
Average Respondent
Table 2a-Yr1
Table 2b-Yr2
Table 2c-Yr3
Average Agency
Labor Rates


Sheet 1: Table 1a-Yr1

Table 1a: Annual Respondent Burden and Cost – NESHAP for Mercury Cell Chlor-Alkali Plants (40 CFR Part 63, Subpart IIIII) (Proposed Rule) - Year 1












121.884 148.806 60.69
Burden Item (A)
Technical person-hours per occurrence
(B)
No. of occurrences per respondent per year
(C)
Technical person-hours per respondent per year
(C=AxB)
(D)
Respondents per year a
(E)
Technical hours per year
(E=CxD)
(F)
Management hours per year
(F=Ex0.05)
(G)
Clerical hours per year
(G=Ex0.10)
(H)
Total cost per year ($) b
1. Recordkeeping requirements







a. Familiarize with regulatory requirements c 32 1 32 1 32 1.6 3.2 $4,333
b. Prepare washdown plan d 16 1 16 0 0 0 0 $0
c. Prepare/review site-specific mercury monitoring plan e 8 1 8 1 8 0.4 0.8 $1,083
d. Record date/time of washdowns 0.1 365 36.5 1 36.5 1.825 3.65 $4,942
e. Measure cell room mercury vapor level and record data 0.5 365 182.5 1 182.5 9.125 18.25 $24,709
f. Monitor vent mercury concentration and record CMS data, daily averages, and deviations 0.5 365 182.5 1 182.5 9.125 18.25 $24,709
g. Perform vent mercury concentration CMS inspections and calibration checks and record results 8 2 16 1 16 0.8 1.6 $2,166
h. Perform twice daily inspections (for vessels and process equipment problems, hydrogen and/or mercury vapor leaks at decomposers and hydrogen piping up to the hydrogen header) and record information 0.75 730 547.5 1 548 27.375 54.75 $74,128
i. Inspect cell room floors for cracks, spalling, or other deficiencies and record information 2 12 24 1 24 1.2 2.4 $3,249
j. Inspect pillars and beams for cracks, spalling, and other deficiencies and record information 8 2 16 1 16 0.8 1.6 $2,166
k. Perform daily cell room inspections (for caustic leaks in caustic system equipment and piping, liquid mercury spills or accumulations on floors and surfaces, for liquid mercury leaks from vessels, piping, and equipment in liquid mercury service) and record information 1.25 365 456.25 1 456.25 22.81 45.625 $61,773
l. Inspect equipment and piping in the hydrogen system from the header to the last control device for hydrogen and/or mercury vapor leaks and record information on these leaks 4 4 16 1 16 0.8 1.6 $2,166
m Record information on handling and storage of mercury-containing waste 0.25 365 91.25 1 91.3 4.56 9.125 $12,355
n. Record the mass of virgin mercury added to cells 0.25 2 0.5 1 0.5 0.025 0.05 $68
o. Inspect chlorine-containing equipment and record information on inspections and leaks 2 730 1460 1 1460 73 146 $197,674
Subtotal for Recordkeeping Requirements




3,529
$415,522
2. Reporting requirements







a. Familiarize with regulatory requirements c See 1A






b. Initial notifications d 6 1 6 0 0 0 0 $0
c. Notification of intent to conduct a performance test d 3 1 3 0 0 0 0 $0
d. Revised Notification of compliance status f 16 1 16 1 16 0.8 1.6 $2,166
e. Semiannual compliance reports 16 2 32 1 32 1.6 3.2 $4,333
Subtotal for Reporting Requirements




55
$6,499
TOTAL ANNUAL BURDEN AND COST (rounded) g




3,580
$422,000
TOTAL CAPITAL AND O&M COSTS (rounded) g






$8,200
GRAND TOTAL (rounded) g






$430,000









Assumptions:







a We have assumed that there are is 1 respondent subject to the rule, with no new sources expected over the next three-years of this ICR.
b This ICR uses the following labor rates: Technical $121.88 ($58.04 + 110%); Managerial $148.81 ($70.86 + 110%); and Clerical $60.69 ($28.90+ 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2020, “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. This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours.
c We assume all respondents will have to familiarize themselves with regulatory requirements each year, including the electronic reporting requirements.
d We assume that these are one-time requirements that have already been met in the past.
e We assume that the facility will review the monitoring plan after the rule revisions are finalized. This is a one-time occurrence.
f We assume that this is a one time event that will occur after the publication of the final amendments.
g Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

Sheet 2: Table 1b-Yr2

Table 1b: Annual Respondent Burden and Cost – NESHAP for Mercury Cell Chlor-Alkali Plants (40 CFR Part 63, Subpart IIIII) (Proposed Rule) - Year 2












121.884 148.806 60.69
Burden Item (A)
Technical person-hours per occurrence
(B)
No. of occurrences per respondent per year
(C)
Technical person-hours per respondent per year
(C=AxB)
(D)
Respondents per year a
(E)
Technical hours per year
(E=CxD)
(F)
Management hours per year
(F=Ex0.05)
(G)
Clerical hours per year
(G=Ex0.10)
(H)
Total cost per year ($) b
1. Recordkeeping requirements







a. Familiarize with regulatory requirements c 32 1 32 1 32 1.6 3.2 $4,333
b. Prepare washdown plan d 16 1 16 0 0 0 0 $0
c. Prepare/review site-specific mercury monitoring plan e 32 1 32 0 0 0 0 $0
d. Record date/time of washdowns 0.1 365 36.5 1 36.5 1.825 3.65 $4,942
e. Measure cell room mercury vapor level and record data 0.5 365 182.5 1 182.5 9.125 18.25 $24,709
f. Monitor vent mercury concentration and record CMS data, daily averages, and deviations 0.5 365 182.5 1 182.5 9.125 18.25 $24,709
g. Perform vent mercury concentration CMS inspections and calibration checks and record results 8 2 16 1 16 0.8 1.6 $2,166
h. Perform twice daily inspections (for vessels and process equipment problems, hydrogen and/or mercury vapor leaks at decomposers and hydrogen piping up to the hydrogen header) and record information 0.75 730 547.5 1 548 27.375 54.75 $74,128
i. Inspect cell room floors for cracks, spalling, or other deficiencies and record information 2 12 24 1 24 1.2 2.4 $3,249
j. Inspect pillars and beams for cracks, spalling, and other deficiencies and record information 8 2 16 1 16 0.8 1.6 $2,166
k. Perform daily cell room inspections (for caustic leaks in caustic system equipment and piping, liquid mercury spills or accumulations on floors and surfaces, for liquid mercury leaks from vessels, piping, and equipment in liquid mercury service) and record information 1.25 365 456.25 1 456.25 22.81 45.625 $61,773
l. Inspect equipment and piping in the hydrogen system from the header to the last control device for hydrogen and/or mercury vapor leaks and record information on these leaks 4 4 16 1 16 0.8 1.6 $2,166
m Record information on handling and storage of mercury-containing waste 0.25 365 91.25 1 91.3 4.56 9.125 $12,355
n. Record the mass of virgin mercury added to cells 0.25 2 0.5 1 0.5 0.025 0.05 $68
o. Inspect chlorine-containing equipment and record information on inspections and leaks 2 730 1460 1 1460 73 146 $197,674
Subtotal for Recordkeeping Requirements




3,520
$414,439
2. Reporting requirements







a. Familiarize with regulatory requirements c See 1A






b. Initial notifications d 6 1 6 0 0 0 0 $0
c. Notification of intent to conduct a performance test d 3 1 3 0 0 0 0 $0
d. Revised Notification of compliance status f 16 1 16 0 0 0 0 $0
e. Semiannual compliance reports 16 2 32 1 32 1.6 3.2 $4,333
Subtotal for Reporting Requirements




37
$4,333
TOTAL ANNUAL BURDEN AND COST (rounded) g




3,560
$419,000
TOTAL CAPITAL AND O&M COSTS (rounded) g






$8,200
GRAND TOTAL (rounded) g






$427,000









Assumptions:







a We have assumed that there are is 1 respondent subject to the rule, with no new sources expected over the next three-years of this ICR.
b This ICR uses the following labor rates: Technical $121.88 ($58.04 + 110%); Managerial $148.81 ($70.86 + 110%); and Clerical $60.69 ($28.90+ 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2020, “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. This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours.
c We assume all respondents will have to familiarize themselves with regulatory requirements each year, including the electronic reporting requirements.
d We assume that these are one-time requirements that have already been met in the past.
e We assume that the facility will review the monitoring plan after the rule revisions are finalized. This is a one-time occurrence.
f We assume that this is a one time event that will occur after the publication of the final amendments.
g Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

Sheet 3: Table 1c-Yr3

Table 1c: Annual Respondent Burden and Cost – NESHAP for Mercury Cell Chlor-Alkali Plants (40 CFR Part 63, Subpart IIIII) (Proposed Rule) - Year 3












121.884 148.806 60.69
Burden Item (A)
Technical person-hours per occurrence
(B)
No. of occurrences per respondent per year
(C)
Technical person-hours per respondent per year
(C=AxB)
(D)
Respondents per year a
(E)
Technical hours per year
(E=CxD)
(F)
Management hours per year
(F=Ex0.05)
(G)
Clerical hours per year
(G=Ex0.10)
(H)
Total cost per year ($) b
1. Recordkeeping requirements







a. Familiarize with regulatory requirements c 32 1 32 1 32 1.6 3.2 $4,333
b. Prepare washdown plan d 16 1 16 0 0 0 0 $0
c. Prepare/review site-specific mercury monitoring plan e 32 1 32 0 0 0 0 $0
d. Record date/time of washdowns 0.1 365 36.5 1 36.5 1.825 3.65 $4,942
e. Measure cell room mercury vapor level and record data 0.5 365 182.5 1 182.5 9.125 18.25 $24,709
f. Monitor vent mercury concentration and record CMS data, daily averages, and deviations 0.5 365 182.5 1 182.5 9.125 18.25 $24,709
g. Perform vent mercury concentration CMS inspections and calibration checks and record results 8 2 16 1 16 0.8 1.6 $2,166
h. Perform twice daily inspections (for vessels and process equipment problems, hydrogen and/or mercury vapor leaks at decomposers and hydrogen piping up to the hydrogen header) and record information 0.75 730 547.5 1 548 27.375 54.75 $74,128
i. Inspect cell room floors for cracks, spalling, or other deficiencies and record information 2 12 24 1 24 1.2 2.4 $3,249
j. Inspect pillars and beams for cracks, spalling, and other deficiencies and record information 8 2 16 1 16 0.8 1.6 $2,166
k. Perform daily cell room inspections (for caustic leaks in caustic system equipment and piping, liquid mercury spills or accumulations on floors and surfaces, for liquid mercury leaks from vessels, piping, and equipment in liquid mercury service) and record information 1.25 365 456.25 1 456.25 22.81 45.625 $61,773
l. Inspect equipment and piping in the hydrogen system from the header to the last control device for hydrogen and/or mercury vapor leaks and record information on these leaks 4 4 16 1 16 0.8 1.6 $2,166
m Record information on handling and storage of mercury-containing waste 0.25 365 91.25 1 91.3 4.56 9.125 $12,355
n. Record the mass of virgin mercury added to cells 0.25 2 0.5 1 0.5 0.025 0.05 $68
o. Inspect chlorine-containing equipment and record information on inspections and leaks 2 730 1460 1 1460 73 146 $197,674
Subtotal for Recordkeeping Requirements




3,520
$414,439
2. Reporting requirements







a. Familiarize with regulatory requirements c See 1A






b. Initial notifications d 6 1 6 0 0 0 0 $0
c. Notification of intent to conduct a performance test d 3 1 3 0 0 0 0 $0
d. Revised Notification of compliance status f 16 1 16 0 0 0 0 $0
e. Semiannual compliance reports 16 2 32 1 32 1.6 3.2 $4,333
Subtotal for Reporting Requirements




37
$4,333
TOTAL ANNUAL BURDEN AND COST (rounded) g




3,560
$419,000
TOTAL CAPITAL AND O&M COSTS (rounded) g






$8,200
GRAND TOTAL (rounded) g






$427,000









Assumptions:







a We have assumed that there are is 1 respondent subject to the rule, with no new sources expected over the next three-years of this ICR.
b This ICR uses the following labor rates: Technical $121.88 ($58.04 + 110%); Managerial $148.81 ($70.86 + 110%); and Clerical $60.69 ($28.90+ 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2020, “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. This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours.
c We assume all respondents will have to familiarize themselves with regulatory requirements each year, including the electronic reporting requirements.
d We assume that these are one-time requirements that have already been met in the past.
e We assume that the facility will review the monitoring plan after the rule revisions are finalized. This is a one-time occurrence.
f We assume that this is a one time event that will occur after the publication of the final amendments.
g Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

Sheet 4: Average Respondent

Annual Respondent Burden and Cost – NESHAP for Mercury Cell Chlor-Alkali Plants (40 CFR Part 63, Subpart IIIII) (Proposed Rule)





Three-Year Average Respondent Burden of Reporting and Recordkeeping Requirements












Year Total Respondents Technical Hours Management Hours Clerical Hours Total Labor Hours (rounded) Labor Cost (rounded)
1 (2021) 1 3,117 156 312 3,580 $430,000
2 (2022) 1 3,093 155 309 3,560 $427,000
3 (2023) 1 3,093 155 309 3,560 $427,000
Total 1 9,303 465 930 10,700 $1,284,000
Average 1 3,101 155 310 3,567 $428,000

Sheet 5: Table 2a-Yr1

Table 2a: Annual EPA Burden and Cost – NESHAP for Mercury Cell Chlor-Alkali Plants (40 CFR Part 63, Subpart IIIII) (Proposed Rule) Year 1












50.72 68.368 27.456
Burden Item (A)
Technical person-hours per occurrence
(B)
No. of occurrences per respondent per year
(C)
Technical person-hours per respondent per year
(C=AxB)
(D)
Respondents per year a
(E)
Technical hours per year
(E=CxD)
(F)
Management hours per year
(F=Ex0.05)
(G)
Clerical hours per year
(G=Ex0.10)
(H)
Total cost per year ($) b
a. Review Initial Notification c 4 1 4 0 0 0 0 $0
b. Review Notification of intent to conduct a performance test c 4 3 12 0 0 0 0 $0
c. Observe performance tests c 16 3 48 0 0 0 0 $0
d. Review Notification of Compliance Status (including site-specific monitoring plans and operation & maintenance plans) d 32 1 32 1 32 1.6 3.2 $1,820
e. Review performance test reports c 8 1 8 0 0 0 0 $0
f. Review semiannual compliance reports e 12 2 24 1 24 1.2 2.4 $1,365.22
TOTAL ANNUAL BURDEN AND COST (rounded) f




64
$3,190









Assumptions:







a We have assumed that there is 1 respondent subject to the rule, with no new sources expected over the next three-years of this ICR.
b This cost is based on the average hourly labor rate as follows: Technical $50.72 (GS-12, Step 1, $30.47 + 60%); Managerial $68.37 (GS-13, Step 5, $41.07 + 60%); and Clerical $27.46 (GS-6, Step 3, $26.38 + 60%). This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. These rates are from the OPM, 2020 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 We assume that this is a one-time only cost.
d Proposed rule requires submittal of a revised Notification of Compliance Status report. We assume that this is a one-time only cost.
e We assume that it will take 12 hours two times per year to review the semiannual compliance reports.
f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

Sheet 6: Table 2b-Yr2

Table 2b: Annual EPA Burden and Cost – NESHAP for Mercury Cell Chlor-Alkali Plants (40 CFR Part 63, Subpart IIIII) (Proposed Rule) Year 2












50.72 68.368 27.456
Burden Item (A)
Technical person-hours per occurrence
(B)
No. of occurrences per respondent per year
(C)
Technical person-hours per respondent per year
(C=AxB)
(D)
Respondents per year a
(E)
Technical hours per year
(E=CxD)
(F)
Management hours per year
(F=Ex0.05)
(G)
Clerical hours per year
(G=Ex0.10)
(H)
Total cost per year ($) b
a. Review Initial Notification c 4 1 4 0 0 0 0 $0
b. Review Notification of intent to conduct a performance test c 4 3 12 0 0 0 0 $0
c. Observe performance tests c 16 3 48 0 0 0 0 $0
d. Review Notification of Compliance Status (including site-specific monitoring plans and operation & maintenance plans) d 32 1 32 0 0 0 0 $0
e. Review performance test reports c 8 1 8 0 0 0 0 $0
f. Review semiannual compliance reports e 12 2 24 1 24 1.2 2.4 $1,365.22
TOTAL ANNUAL BURDEN AND COST (rounded) f




28
$1,370









Assumptions:







a We have assumed that there is 1 respondent subject to the rule, with no new sources expected over the next three-years of this ICR.
b This cost is based on the average hourly labor rate as follows: Technical $50.72 (GS-12, Step 1, $30.47 + 60%); Managerial $68.37 (GS-13, Step 5, $41.07 + 60%); and Clerical $27.46 (GS-6, Step 3, $26.38 + 60%). This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. These rates are from the OPM, 2020 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 We assume that this is a one-time only cost.
d Proposed rule requires submittal of a revised Notification of Compliance Status report. We assume that this is a one-time only cost.
e We assume that it will take 12 hours two times per year to review the semiannual compliance reports.
f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

Sheet 7: Table 2c-Yr3

Table 2c: Annual EPA Burden and Cost – NESHAP for Mercury Cell Chlor-Alkali Plants (40 CFR Part 63, Subpart IIIII) (Proposed Rule) Year 3












50.72 68.368 27.456
Burden Item (A)
Technical person-hours per occurrence
(B)
No. of occurrences per respondent per year
(C)
Technical person-hours per respondent per year
(C=AxB)
(D)
Respondents per year a
(E)
Technical hours per year
(E=CxD)
(F)
Management hours per year
(F=Ex0.05)
(G)
Clerical hours per year
(G=Ex0.10)
(H)
Total cost per year ($) b
a. Review Initial Notification c 4 1 4 0 0 0 0 $0
b. Review Notification of intent to conduct a performance test c 4 3 12 0 0 0 0 $0
c. Observe performance tests c 16 3 48 0 0 0 0 $0
d. Review Notification of Compliance Status (including site-specific monitoring plans and operation & maintenance plans) d 32 1 32 0 0 0 0 $0
e. Review performance test reports c 8 1 8 0 0 0 0 $0
f. Review semiannual compliance reports e 12 2 24 1 24 1.2 2.4 $1,365.22
TOTAL ANNUAL BURDEN AND COST (rounded) f




28
$1,370









Assumptions:







a We have assumed that there is 1 respondent subject to the rule, with no new sources expected over the next three-years of this ICR.
b This cost is based on the average hourly labor rate as follows: Technical $50.72 (GS-12, Step 1, $30.47 + 60%); Managerial $68.37 (GS-13, Step 5, $41.07 + 60%); and Clerical $27.46 (GS-6, Step 3, $26.38 + 60%). This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. These rates are from the OPM, 2020 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 We assume that this is a one-time only cost.
d Proposed rule requires submittal of a revised Notification of Compliance Status report. We assume that this is a one-time only cost.
e We assume that it will take 12 hours two times per year to review the semiannual compliance reports.
f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

Sheet 8: Average Agency

Annual Respondent Burden and Cost – NESHAP for Mercury Cell Chlor-Alkali Plants (40 CFR Part 63, Subpart IIIII) (Proposed Rule)





Three-Year Average Agency Burden of Reporting and Recordkeeping Requirements



















Year Total Respondents Technical Hours Management Hours Clerical Hours Total Labor Hours Labor Cost (rounded)
1 (2021) 1 56 3 6 64 $3,190
2 (2022) 1 24 1 2 28 $1,370
3 (2023) 1 24 1 2 28 $1,370
Total 1 104 5 10 120 $5,930
Average 1 35 2 3 40 $1,977

Sheet 9: Labor Rates


Labor Rate ($/hr) Overhead Total ($/hr)

110%
Respondent Burden



Managerial $70.86 $77.95 $148.81
Technical $58.04 $63.84 $121.88
Clerical $28.90 $31.79 $60.69










United States Department of Labor, Bureau of Labor Statistics, “Table 2. Civilian Workers, by occupational and industry group.” The rates are from column 1, “Total compensation.” For the 2019 renewal, these rates were from June 2018. For the updated rates, the rates were from June 2020. The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry.

















Labor Rates ($/hr) Overhead Benefit Package Adjustment

60% 60%
Agency Burden



Managerial $42.73 $25.64 $68.37 GS13, Step 5
Technical $31.70 $19.02 $50.72 GS12, Step 1
Clerical $17.16 $10.30 $27.46 GS6, Step 3










Office of Personnel Management (OPM), which excludes locality rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees. These rates are from the 2020 General Schedule.
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