Burden Tables

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Overview

Table 1
Table 2
O&M

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Sheet 1: Table 1

Table 1: Annual Respondent Burden and Cost – NESHAP for Epoxy Resin and Non-Nylon Polyamide Production (40 CFR Part 63, Subpart W) (Renewal)
Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (A x B)	(D) Respondents per year a	(E) Technical person- hours per year (C x D)	(F) Management person hours per year (E x0.05)	(G) Clerical person hours per year (E x 0.1)	(H) Total Cost per year b
1. Applications	N/A									Labor Rates
2. Surveys and studies	N/A									Management	$148.45
3. Reporting requirements										Technical	$121.46
A. Familiarization with the regulatory requirements a	1	1	1	7	7	0.4	0.7	$944		Clerical	$60.23
B. Required activities c
Basic liquid resins (BLR)	1,050	1	1,050	0	0	0	0	$0
Repeat initial performance test - process vents	1,050	1	1,050	0	0	0	0	$0
Initial performance test - wastewater	270	1	270	0	0	0	0	$0
Repeat initial performance test – wastewater	270	1	270	0	0	0	0	$0
Wet strength resins (WSR) d	270	1	270	0	0	0	0	$0
C. Create information	See 3B, 4D, 4E
D. Gather existing information	See 3B, 4D, 4E
E. Write report
Notification of construction/reconstruction c	2	1	2	0	0	0	0	$0
Notification of physical/operational changes e	2	1	2	1	2	0.1	0.2	$269.81
Notification of anticipated startup c	2	1	2	0	0	0	0	$0
Notification of actual startup c	2	1	2	0	0	0	0	$0
Notification of applicability of the standard – existing sources c	2	1	2	0	0	0	0	$0
Notification of applicability of the standard – new sources c	2	1	2	0	0	0	0	$0
Notification of initial performance test c	2	1	2	0	0	0	0	$0
Report of initial test (including CMS performance evaluation and results) c	6	1	6	0	0	0	0	$0
Submit quality control plan for CMS c, f	2	1	2	0	0	0	0	$0
Submit startup, shutdown, malfunction plan c	2	1	2	0	0	0	0	$0
Report of monitoring exceedances and periods of noncompliance g	16	4	64	1	64	3.2	6.4	$8,633.95
Report of no excess emissions h	8	4	32	6	192	9.6	19.2	$25,901.86
Report of area source becoming major i	6	1	6	0	0	0	0	$0
Waiver application j	6	1	6	1	6	0.3	0.6	$809.43
Compliance status information report c	4	1	4	0	0	0	0	$0
Submit semiannual SSM reports k	2	2	4	7	28	1.4	2.8	$3,777.35
Submit immediate reports of inconsistent procedures monitored at each affected source h	2	1	2	7	14	0.7	1.4	$1,888.68
Submit a CMS summary report for HAP monitored at each affected source l	2	1	2	3	6	0.3	0.6	$809.43
Subtotal for Reporting Requirements					367			$43,035
4. Recordkeeping requirements
A. Familiarization with the regulatory requirements a	See 3A
B. Plan activities	N/A
C. Implement activities	See 4D, 4E
D. Develop record system c	40	1	40	0	0	0	0	$0
E. Time to enter information
a. Records of control device monitoring parameters:
- Continuously monitored parameters l, m	12	52	624	3	1,872	94	187	$252,543.10
- LDAR program reporting and recordkeeping – BLR l	311	1	311	3	933	47	93	$125,866.83
- LDAR program reporting and recordkeeping – WSR n	11	1	11	4	44	2.2	4.4	$5,935.84
- Wastewater parameters l, o	2	12	24	3	72	3.6	7.2	$9,713.20
F. Other recordkeeping activities
a. Maintain records of occurrence and duration of each SSM of process and control equipment h, p	2	8	16	7	112	5.6	11	$15,109.42
b. Maintain records of maintenance performed on air pollution control equipment h	2	4	8	7	56	2.8	5.6	$7,554.71
c. Maintain records of all action taken during periods of SSM that differ from the sources SSM plan h, q	2	1	2	7	14	0.7	1.4	$1,888.68
d. Maintain records of each period during which a CMS is malfunctioning or inoperative l	2	1	2	3	6	0.3	0.6	$809.43
e. Maintain records of result of all performance test and performance evaluations c	2	1	2	0	0	0	0	$0
f. Maintain all initial notification and compliance status notifications c	1	1	1	0	0	0	0	$0
G. Time for audits	N/A
Subtotal for Recordkeeping Requirements					3,575			$419,421
Total Labor Burden and Costs (rounded) r					3,940			$462,000		Number of responses	54
Total Capital and O&M Cost (rounded) r								$14,000		Hours per response	73
Grand Total (rounded) r								$476,000
Assumptions:
a We have assumed that the average number of existing sources subject to the rule will be seven, which consists of three basic liquid epoxy resins (BLR) plants and four wet strength resins (WSR) plants. There will be no additional new sources per year that will become subject to the rule over the three-year period of this ICR. We assume that each respondent will have to familiarize with the regulatory requirements each year.
b This ICR uses the following labor rates for privately-owned sources: $148.45 for managerial, $121.46 for technical, and $60.23 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 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.
c We have assumed that this is a one-time-only cost. Records for one-time reporting activities must only be retained for five years. The five year period after these initial activities precedes the period covered by this ICR renewal.
d For all wet strength resins (WSR) facilities, as an alternative to implementing the standards for process vents, storage tanks, and wastewater, these facilities may elect to comply with the requirements of 40 CFR part 63, subpart H - leak detection and repair program for equipment leaks. Because it is more cost effective, we have assumed that all WSR facilities will choose to comply with the alternative standard. These facilities are not required to have the continuous monitoring systems (CMS) installed.
e We have assumed that one facility will have a physical or operational change.
f We have assumed that it will require one test each for wastewater and process vents.
g We have assumed that only one facility will have excess emissions.
h We have assumed that there are seven sources that are subject to this regulation, so the number of sources without excess emissions report is six.
i We have assumed that no area sources are expected to become major sources.
j We have assumed that one facility will require a waiver.
k We have assumed that it will take each respondent two hours to submit semiannual (SSM) reports. Also quarterly reporting may be reduced to semiannual reporting for sources that are in compliance for one year.
l We have assumed that there are three basic liquid resins (BLR) manufacturing facilities.
m We have assumed that these parameters will automatically be recorded with a data logger.
n We have assumed that there are four WSR facilities subject to the rule.
o We have assumed that it will take two hours to record wastewater parameters during the monthly monitoring.
p We have assumed that startup, shutdown, and/or malfunction (SSM) will occur eight times per year for each facility.
q We have assumed that it will take two hours once per year for each facility to maintain records for one deviation from SSM plans.
r 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 and Cost – NESHAP for Epoxy Resin and Non-Nylon Polyamide Production (40 CFR Part 63, Subpart W) (Renewal)
Activity	(A) EPA person- hours per occurrence	(B) No. of occurrences per plant per year	(C) EPA person- hours per plant per year (AxB)	(D) Plants per year a	(E) Technical person- hours per year (CxD)	(F) Management person-hours per year (Ex0.05)	(G) Clerical person-hours per year (Ex0.1)	(H) Cost, $ b
Report review										Labor Rates
Notification of construction/reconstruction and startup c	2	1	2	0	0	0	0	$0		Management	$68.37
Notification of physical and operational changes d	2	1	2	1	2	0.1	0.2	$113.77		Technical	$50.72
Notification of anticipated startup c	2	1	2	0	0	0	0	$0		Clerical	$27.46
Notification of actual startup c	2	1	2	0	0	0	0	$0
Notification of applicability of the standard new sources c	2	1	2	0	0	0	0	$0
Notification of initial performance test c	2	1	2	0	0	0	0	$0
Report of initial test c	8	1	8	0	0	0	0	$0
Startup, shutdown, malfunction plan c	4	1	4	0	0	0	0	$0
Quality control plan for CMS c	4	1	4	0	0	0	0	$0
Semiannual SSM reports e. f	4	2	8	7	56	2.8	5.6	$3,185.53
CMS summary report for HAP	4	1	4	3	12	0.6	1.2	$682.61
Immediate reports of inconsistent procedures	4	1	4	7	28	1.4	2.8	$1,592.77
Report of monitoring exceedances and periods of noncompliance g	8	4	32	1	32	1.6	3.2	$1,820.30
Report of no excess emission	2	4	8	6	48	2.4	4.8	$2,730.46
Waiver application h	8	1	8	1	8	0.4	0.8	$455.08
TOTAL (rounded) i					214			$10,600
Assumptions:
a We have assumed that the average number of existing sources subject to the rule will be seven, which consists of three liquid epoxy resins (BLR) plants and four wet strength resins (WSR) plants. There will be no additional new sources per year that will become subject to the rule over the three-year period of this ICR.
b This ICR uses the following labor rates: $68.37 for managerial, $50.72 for technical, and $27.46 for clerical labor. These rates are from the Office of Personnel Management (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 have assumed that this is a one-time-only cost.
d We have assumed that only one facility will conduct some form of physical or operational change.
e We have assumed that there are 7 sources that are subject to this regulation that report semiannually.
f We have assumed that it will take four hours to review semiannual reports.
g We have assumed that one facility will have excess emissions.
h We have assumed that one facility will request a waiver.
i Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: O&M

								Total Annual Responses
Number of Respondents								(A)	(B)	(C)	(D)	(E)
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports					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
	(A)	(B)	(C)	(D)	(E)			Notification of physical and operational changes	1	1	N/A	1
Year	Number of New Respondents 1	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)			Report of monitoring exceedances and periods of noncompliance	1	4	N/A	4
1	1	7	0	1	7			Report of no excess emissions	6	4	N/A	24
2	1	7	0	1	7			Waiver application	1	1		1
3	1	7	0	1	7			SSM report	7	2	N/A	14
Average	1	7	0	1	7			Immediate report of inconsistent procedures	7	1	N/A	7
1 New respondents include sources with constructed, reconstructed and modified affected facilities.								CMS summary report	3	1	N/A	3
											Total	54
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)		1998 CEPCI CE Index	389.5
Continuous Monitoring System a, b	$3,899	0	$0	$4,679	3	$14,037		2019 CEPCI CE Index	607.5
Total c			$0			$14,000
a There are 3 BLR facilities and 4 WSR facilities, for a total of 7 respondents. We assume all 4 WSR facilities will choose to comply with the alternative standard at 40 CFR Part 63, Subpart H for leak detection and repair program for equipment leaks. Therefore, they are not required to have CMS installed.
b Capital/startup costs and O&M costs have been updated from 1998 dollars to 2019 dollars using the CEPCI CE Index.
c Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.