Burden Calculation Tables

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Overview

Capital and O&M Costs
# Responses Calcs
Respondent Burden
Agency Burden

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Sheet 1: Capital and O&M Costs

Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A)	(B)	(C)	(D)	(E)	(F)	(G)
Data Collection Device	Capital/Startup Cost for One Model/Unit	Number of New Models/Units	Total Capital/Startup Cost, (B X C)	Annual O&M Costs for One Model/Unit	Number of Models/ Units with O&M	Total O&M, (E X F)
None	$0	0	$0	$0	0	$0
Total			$0			$0

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Sheet 2: # Responses Calcs

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 construction/reconstruction	0	1	0	0
Notification of anticipated startup	0	1	0	0
Notification of actual startup	0	1	0	0
Initial notification of applicability	0	1	0	0
Waiver application	0	1	0	0
Alternative test method/monitoring application	0	1	0	0
Site-specific test plan	0	1	0	0
Notification of initial compliance test date	0	1	0	0
Notification of compliance status	0	1	0	0
Notification of changes in information provided to Administrator	0	1	0	0
Request for extension of compliance	0	1	0	0
Extension of compliance progress reports	0	1	0	0
Report of performance test/evaluation results	0	1	0	0
Annual excess emissions and monitoring exceedances and/or summary report(s)	38	1	0	38
Report of HAP control efficiency	38	1	0	38
Retain records of emissions estimates and actual throughput	0	1	766	766
Total (after rounding)				842

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Sheet 3: Respondent Burden

Table 1: Annual Respondent Burden and Cost – NESHAP for Marine Tank Vessel Loading Operations (40 CFR Part 63, Subpart Y) (Renewal)
Burden Item	A	B	C	D	E	F	G	H		TECH	$121.46
	Technical person-hours per occurrence	No. of occurrences per respondent per year	Technical person-hours per respondent per year (AxB)	Respondents per year a	Technical hours per year (CxD)	Management hours per year (Ex0.05)	Clerical hours per year (Ex0.10)	Total cost per year ($) b		MGMT	$148.45
1. Applications	N/A									CLER	$60.23
2. Survey and studies	N/A
3. Reporting requirements										0	New Respondents
A. Familiarization with Regulatory Requirements a	1	1	1	804	804	40.2	80.4	$108,464.02		38	Existing Respondents
B. Required activities										766	Recordkeeping Only
Performance test c, d	280	1	280	0	0	0	0	$0
Repeat performance test d, e	280	1	280	0	0	0	0	$0
Annual leak check f	16	1	16	38	608	30.4	60.8	$82,022.54
Annual vapor tightness check g, h, i	8	1	8	450	3,600	180	360	$485,659.80
C. Create information	See 3B
D. Gather existing information	See 3E
E. Write report
Notification of construction/reconstructionc	2	1	2	0	0	0	0	$0
Notification of anticipated startupc	2	1	2	0	0	0	0	$0
Notification of actual startupc	2	1	2	0	0	0	0	$0
Initial notification of applicabilityc	4	1	4	0	0	0	0	$0
Waiver application c,j	2	1	2	0	0	0	0	$0
Alternative test method/monitoring application c,k	1	1	1	0	0	0	0	$0
Site-specific test planc	See 3B
Notification of initial compliance test datec	2	1	2	0	0	0	0	$0
Notification of compliance statusc	See 3B
Notification of changes in information provided to Administratorc	1	1	1	0	0	0	0	$0
Request for extension of compliancec	1	1	1	0	0	0	0	$0
Extension of compliance progress reportsc	1	1	1	0	0	0	0	$0
Report of performance test/evaluation resultsc	1	1	1	0	0	0	0	$0
Annual excess emissions and monitoring exceedances and/or summary report(s) l	32	1	32	38	1,216	60.8	121.6	$164,045.09
Report of HAP control efficiency m	8	1	8	38	304	15.2	30.4	$41,011.27
Reporting Subtotal					7,512			$881,202.73
4. Recordkeeping requirements
A. Familiarization with Regulatory Requirements a	See 3A
B. Plan activities	N/A
C. Implement activitiesc	16	1	16	0	0	0	0	$0
D. Develop record systemc	16	1	16	0	0	0	0	$0
E. Time to enter information n	1	52	52	38	1,976	98.8	197.6	$266,573.27
F. Time to train personnel	N/A
G. Time to transmit or disclose information	1	1	1	38	38	1.9	3.8	$5,126.41
H. Retain records of emissions estimates and actual throughput (facilities with HAP emissions less than 10 and 20 tons) o	1	1	1	766	766	38.3	76.6	$103,337.61
I. Time for audits	N/A
Recordkeeping Subtotal					3,197			$375,037.29
TOTAL LABOR BURDEN AND COST (rounded)p					10,700			$1,260,000
TOTAL CAPITAL AND O&M COST (rounded)p								$0
GRAND TOTAL (rounded)p								$1,260,000
N/A - Not Apllicable							13	hrs/response
Assumptions:
a. We have assumed the average number of existing sources subject to the rule over the three-year period of this ICR will be 804. Of the 804 existing sources, 38 are currently subject to the emissions standard. The remaining 766 sources are not subject to the emissions standards but are subject to some recordkeeping requirements. We assume that each respondent will have to familiarize with the regulatory requirements each year.
b. This ICR uses the following labor rates: $121.46 for technical, $148.45 for managerial, 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 this is a one-time-only cost.
d. We have assumed it will take each respondent subject to emission standards 280 hours to complete the performance test.
e. We have assumed 15 percent of respondents subject to initial performance test will repeat performance test due to failure.
f. We have assumed it will take each respondent subject to emission standards 16 hours once per year to complete annual leak checks.
g. We have assumed that this burden applies to marine vessels owners, and not to the affected sources. There is an estimated 450 owners for the 804 sources.
h. We have assumed it will take each respondent eight hours once per year to complete annual vapor tightness check.
i. This number is based on factors calculated for the original ICR in 1995. This ICR uses fleet factor and affected facility throughout and then divides it in half. We have assumed that half of the facilities load at negative pressure.
j. We have assumed five percent of respondents subject to emission standards will request a waiver.
k. We have assumed one percent of respondents subject to emission standards will request either alternative test or monitoring methods.
l. We have assumed it will take each respondent subject to emission standards 32 hours once per year to complete the ongoing compliance status report. Semiannual reports are required when there are excess emissions. We have assumed there will be no excess emissions; therefore, each respondent will submit one excess emissions and monitoring exceedances and/or summary report(s) once per year.
m. We have assumed it will take each respondent subject to emission standards 8 hours once per year to complete the HAP control efficiency report.
n. We have assumed it will take each respondent subject to emission standards 1 hour to enter information 52 times per year.
o. This requirement only applies to facilities not subject to emission standards.												the old footnote did not seem to make snese for this line item, which is not reporting just recordkeeping. Edited foonote text. The old footnote seems to be footnote l, so i moved this up. OLD FOOTNOTE READ: Semiannual reports are required when there are excess emissions. We have assumed there will be no excess emissions; therefore, each respondent will submit one excess emissions and monitoring exceedances and/or summary report(s) once per year.
p. Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 4: Agency Burden

Table 2: Average Annual EPA Burden and Cost – NESHAP for Marine Tank Vessel Loading Operations (40 CFR Part 63, Subpart Y) (Renewal)
										TECH	$50.72
Burden Item	(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		MGMT	$68.37
Initial performance test	40	1	40	0	0	0	0	$0		CLER	$27.46
Repeat performance test	40	1	40	0	0	0	0	$0
Report Review
Notification of construction/reconstruction c	2	1	2	0	0	0	0	$0
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
Initial notification of applicability reportc	2	1	2	0	0	0	0	$0
Waiver application c, d	2	1	2	0	0	0	0	$0
Review alternative test method/monitoring application c, e	1	1	1	0	0	0	0	$0
Notification of initial compliance test date c	2	1	2	0	0	0	0	$0
Notification of compliance status c,f	2	1	2	0	0	0	0	$0
Review of annual excess emissions and monitoring exceedances and/or summary report(s) g	8	1	8	38	304	15.2	30.4	$17,292.89
Report of HAP control efficiency h	8	1	8	38	304	15.2	30.4	$17,292.89
TOTAL ANNUAL BURDEN AND COST (rounded)i					699			$34,600
Assumptions:
a. We have assumed the average number of existing sources subject to the rule over the three-year period of this ICR will be 804. Of the 804 existing sources, 38 are currently subject to the emissions standard. The remaining 766 sources are not subject to the emissions standards but are subject to some recordkeeping requirements.															modified footnotes throughout to clarify respondents as "respondents subject to emission standards" when it is referring to the 38 instead of all sources.
b. This ICR uses the following labor rates: $50.72 for technical, $68.37 for managerial, 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 this is a one-time-only cost.
d. We have assumed 5 percent of respondents subject to emission standards will request a waiver.
e. We have assumed 1 percent of respondents subject to emission standards will request alternative test or monitoring methods.
f. We have assumed each respondent will take 2 hours once per year to review the compliance status report.
g. Semiannual reports are required when there are excess emissions. We have assumed there will be no excess emissions; therefore, each respondent subject to emission standards will submit one excess emissions and monitoring exceedances and/or summary report(s) once per year.
h. We have assumed each of the 38 existing sources currently subject to the emissions standard will take eight hours once per year to complete the HAP control efficiency report.
i. Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.