Burden Calculations

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Overview

Table 1
Table 2

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Sheet 1: Table 1

Table 1: Annual Respondent Burden and Cost – NESHAP for Vinyl Chloride (40 CFR Part 61, Subpart F) (Renewal)
					122.66	149.84	60.88
Burden item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Person-‌hours per occurrence	No. of occurrences per respondent per year	Person- hours per respondent per year (C=AxB)	Respondents per year a	Technical person- hours per year (E=CxD)	Management person-hours per year (F=Ex0.05)	Clerical person-hours per year (G=Ex0.1)	Cost ($) b
1. Applications	N/A
2. Survey and Studies	N/A
3. Reporting requirements
A. Familiarize with regulatory requirements c	1	4	4	16	64	3.2	6.4	$8,719.36
B. Required activities
Initial performance test d	60	1	60	0	0	0	0	$0
Repeat performance tests e	60	0.2	12	0	0	0	0	$0
C. Create information	See 3B
D. Gather existing information	See 3B
E. Write Report
Notification of construction/reconstruction	2	1	2	0	0	0	0	$0
Notification of anticipated startup	2	1	2	0	0	0	0	$0
Notification of actual startup	2	1	2	0	0	0	0	$0
Notification of emission testing	2	1	2	0	0	0	0	$0
Notification of test report	2	1	2	0	0	0	0	$0
Notification of physical or operational change f	2	1	2	0	0	0	0	$0
Application for waiver of testing g	8	1	8	0	0	0	0	$0
Application of equivalency h	40	1	40	0	0	0	0	$0
Initial report	24	1	24	0	0	0	0	$0
Quarterly report i	50	4	200	16	3,200	160	320	$435,968.00
MVV/RVD report j	8	1	8	16	128	6.4	12.8	$17,438.72
Subtotal for Reporting Requirements					3,901			$462,126
4. Recordkeeping requirements
A. Familiarize with regulatory requirements	See 3A
B. Plan activities	See 3B
C. Implement Activities	See 3D
D. Develop record system	N/A
E. Time to enter information
Records of reactor parameters and emission k	0.25	365	91.25	16	1,460	73	146	$198,910.40
Records of leaks detected l	1	52	52	16	832	41.6	83.2	$113,351.68
F. Time to train personnel	N/A
G. Time for audits	N/A
Subtotal for Recordkeeping Requirements					2,636			$312,262		responses	hr/response
TOTAL ANNUAL BURDEN AND LABOR COST (rounded) m					6,540			$774,000		80	82
TOTAL CAPITAL AND O&M COST (rounded) m								$720,000
GRAND TOTAL (rounded) m								$1,490,000
Assumptions:
a We estimate there are 16 existing sources subject to the standard and no additional sources will become subject over the three-year period of this ICR.
b This ICR uses the following labor rates: $149.84 for managerial labor, $122.66 for technical labor, and $60.88 for clerical labor. These rates are from the U.S. Department of Labor, Bureau of Labor Statistics, September 2020. The rates have been increased by 110 percent to account for overhead.
c We have assumed that all sources will have to familiarize with the regulatory requirements quarterly.
d We have assumed that it will take 60 hours to complete the performance tests.
e We have assumed that 20 percent of initial performance tests must be repeated due to failure.
f Assumed that there will be no physical or operational changes over the next three years.
g Assume it will take eight hours to prepare application for waiver of testing.
h Assume it will take 40 hours to prepare application for equivalency.
i We have assumed that it will take 50 hours to prepare the quarterly report.
j We have estimated that there will be one manual vent valve/relief valve discharge (MVV/RVD) per year.
k Assume that affected facilities will operate 365 days per year as required of all facilities that are subject to the rule.
l It is estimated that respondents will enter records of leak detection 52 times per year.
m 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 Vinyl Chloride (40 CFR Part 61, Subpart F) (Renewal)
					51.23	69.04	27.73
Activity	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	EPA person- hours per occurrence	No. of occurrences per plant per year	EPA person-hours per plant per year (C=AxB)	Plants per year	Technical person- hours per year (E=CxD)	Management person-hours per year (F=Ex0.05)	Clerical person-hours per year (G=Ex0.1)	Cost ($) b
1. Initial performance test c	24	1	24	0	0	0	0	$0
2. Repeat performance test d	24	0.2	4.8	0	0	0	0	$0
3. Report review
Notification of construction/reconstruction	1	1	1	0	0	0	0	$0
Notification of anticipated startup	0.5	1	0.5	0	0	0	0	$0
Notification of actual startup	0.5	1	0.5	0	0	0	0	$0
Notification of emission testing	0.5	1	0.5	0	0	0	0	$0
Notification of physical or operational change e	0.5	1	0.5	0	0	0	0	$0
Emission test report f	24	1	24	0	0	0	0	$0
Application for waiver of testing g	24	1	24	0	0	0	0	$0
Application for equivalency	24	1	24	0	0	0	0	$0
Initial report	24	1	24	0	0	0	0	$0
Quarterly report h	4	4	16	16	256	12.8	25.6	$14,708.48
MVV/RVD report i	24	1	24	16	384	19.2	38.4	$22,062.72
TOTAL ANNUAL BURDEN (rounded) j					736			$36,800
Assumptions:
a We estimate there are 16 existing sources subject to the standard and no additional sources will become subject over the three-year period of this ICR.
b This cost is based on the following hourly labor rates times a 1.6 benefits multiplication factor to account for government overhead expenses: $69.04 for Managerial (GS-13, Step 5, $43.15 x 1.6), $51.23 for Technical (GS-12, Step 1, $32.02 x 1.6) and $27.73 Clerical (GS-6, Step 3, $17.33 x 1.6). These rates are from the Office of Personnel Management (OPM) 2021 General Schedule which excludes locality rates of pay.
c We have assumed that it will take twenty-four hours to complete the performance tests.
d We have assumed that 20 percent of initial performance tests must be repeated due to failure.
e Assume that there will be no physical or operational changes over the next three years.
f It is assumed that it will take twenty-four hours to review an emissions test report.
g Assume that it will take twenty-four hours to review application for waiver of test.
h We have assumed that it will take four hours to review the quarterly report.
i We have assumed that there will be one manual vent valve/relief valve discharge (MVV/RVD) per year.
j Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.