Burden Calculation Tables

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Overview

Industry
Agency
Capital O&M
Annual Responses

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Sheet 1: Industry

Table 1: Annual Respondent Burden and Cost – NESHAP for Printing, Coating and Dyeing of Fabrics and Other Textiles (40 CFR Part 63, Subpart OOOO) (Renewal)
					122.2	153.55	61.51
Burden item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Person - hours per occurrence	No. of occurrence per respondent per year	Person-hours per respondent per year	Respondents per year a	Technical Person - hours per year	Management person-hours per year	Clerical person - hours per year	Cost, $ b
			(C=AxB)		(E=CxD)	(Ex0.05)	(Ex0.1)				36	coating and printing facilities			(do NOT sum, overlap in operations)
1. Applications	N/A										12	slashing, dyeing, and finishing facilities
2. Survey and Studies	N/A
3. Reporting Requirements											44	Total (added 1 based on ECHO and permit; permit application lists affected processes as web coating and printing quipment)
A. Familiarization with rule requirement	4	1	4	44	176	8.8	17.6	$23,941.02
B. Required activities
Initial oxidizer performance test c, e	280	1	280	0	0	0	0	$0
Repeat oxidizer performance test c, e, f	280	1	280	0	0	0	0	$0
Initial capture performance test c, e	215	1	215	0	0	0	0	$0
Repeat capture performance test c, e, f	215	1	215	0	0	0	0	$0
Periodic add-on control device performance test j	30	0.33	10	20	200	10	20	$27,206
Repeat of periodic add-on control device performance test j	30	0.33	10	1	10	0.5	1	$1,360
Solvent recovery system compliance determination c, p	4	12	48	7.4	355.2	17.76	35.52	$48,317.32
Emission rate limit compliance determination	4	12	48	44	2,112	105.6	211.2	$287,292.19
Coordination with suppliers g	40	1	40	44	1,760	88	176	$239,410.16
C. Create information	See 4B
D. Gather existing information	See 4B
E. Write report
Initial notification c	2	1	2	0	0	0	0	$0
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
Notification of compliance status c	4	1	4	0	0	0	0	$0
Notification of performance test c, e	2	1	2	0	0	0	0	$0
Performance test report c, e	40	1	40	0	0	0	0	$0
Notification of performance test (add-on control) j	2	0.33	0.66	21	13.86	0.693	1.386	$1,885
Performance test report (add-on control) j	10	0.33	3.3	21	69.3	3.465	6.93	$9,427
Report of monitoring exceedances c, h, k	16	2	32	3.7	118.4	5.92	11.84	$16,105.77
Report of no excess emissions c, i, k	8	2	16	33.3	533	26.64	53.28	$72,475.98
Report of compliance deviation d, k, l	16	2	32	1.2	38.4	1.92	3.84	$5,223.49
Report of no compliance deviations d, k, m	8	2	16	10.8	173	8.64	17.28	$23,505.72
Subtotal for Reporting Requirements					6,393			$756,149.78
4. Recordkeeping Requirements
A. Familiarization with rule requirement	See 4B
B. Plan activities	N/A
C. Implement activities	N/A
D. Develop record system	N/A
E. Time to enter information
Records of all information required by standards n	0.25	52	13	44	572	28.6	57.2	$77,808.30
F. Time to train personnel	N/A
G. Time to adjust existing ways to comply with previously applicable requirements	N/A
H. Time to transmit or disclose information o	0.25	2	0.5	44	22	1.1	2.2	$2,992.63
I. Time for audits	N/A
Subtotal for Recordkeeping Requirements					683			$80,800.93
TOTAL LABOR BURDEN AND COSTS q					7,080			$837,000
TOTAL CAPITAL AND O&M COST q								$123,000
TOTAL COST: q								$960,000
Assumptions:
a We have assumed that the average number of respondents that will be subject to the rule will be 44, which equates to 37 coating and printing sources, and 12 slashing, dyeing, and finishing sources. 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: $153.55 per hour for Executive, Administrative, and Managerial labor; $122.20 per hour for Technical labor, and $61.51 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2021, “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 applies only to coating and printing facilities.
d This applies only to slashing, dyeing and finishing facilities.
e Occurs one time for new sources and involves one-time startup costs associated with initial compliance determination and acquisition, installation, and utilization of technology and systems needed to support recordkeeping and reporting.
f It is assumed that 5 percent of respondents will have to repeat performance tests.
g We have assumed that it will take 40 hours for each respondent to coordinate with suppliers.
h We have assumed that 10 percent of respondents will report monitoring exceedances.
i We have assumed that 90 percent of respondents will report no excess emissions.
j Facilities that comply with the 2019 amendment using emission capture systems and add-on controls will conduct air emissions performance testing, within 3 years of the effective date of the revised standards and no less frequently than once every five years thereafter. Twenty add-on controls and would require periodic testing. The twenty does not include other lines also with add-on controls that are already required to periodically test because of state operating permit conditions. As these tests are conducted only once during the three-year period of this ICR, the number of occurrences per respondent per year is 0.33 (1/3=0.33). It is assumed that 5 percent of respondents will have to repeat performance tests.
k Semiannual reports are required.
l It is assumed that 10 percent of respondents will report compliance deviations.
m It is assumed that 90 percent of respondents will report no compliance deviations.
n It is assumed that all of the respondents will be required to record information on a weekly basis.
o It is assumed that respondents will be required to transmit/disclose information on a semiannual basis.
p It is assumed that 20 percent of the coating and printing facilities will use solvent recovery equipment.
q Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 2: Agency

Table 2: Average Annual EPA Burden and Cost – NESHAP for Printing, Coating and Dyeing of Fabrics and Other Textiles (40 CFR Part 63, Subpart OOOO) (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	Plants per year a	Technical person-hours per year	Management person-hours per year	Clerical person- hours per year	Cost, $ b
			(C=AxB)		(E=CxD)	(Ex0.05)	(Ex0.1)				36	coating and printing facilities			Updated # of operations
1. Initial performance test c	495	1	495	0	0	0	0	$0			12	slashing, dyeing, and finishing facilities			Updated # of operations
2. Repeat performance test preparations c, e	4	0.1	0.4	0	0	0	0	$0			43	Total			Updated to total # sources (does not sum)
3. Repeat performance test c, e	495	0.1	49.5	0	0	0	0	$0			44	Total (added 1 based on ECHO and permit; permit application lists affected processes as web coating and printing quipment)
4. Periodic add-on control device performance test i	24	0.33	8	20	160	8	16	$9,193
5. Repeat of periodic add-on control device performance test i	24	0.33	8	1	8	0.4	0.8	$460
6. Report Review
Notification of applicability	2	1	2	0	0	0	0	$0
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 initial performance test c	2	1	2	0	0	0	0	$0
Notification of performance test (add-on control) i	10	0.33	3.33	21	70.00	3.50	7.00	$4,022
Performance test report (add-on control) i	20	0.33	6.67	21	140.00	7.00	14.00	$8,044
Notification of compliance status c	2	1	2	0	0	0	0	$0
Review of initial performance test report c	8	1	8	0	0	0	0	$0
Review of repeat performance test report c, f	8	0.1	0.8	0	0	0	0	$0
Review of excess emissions report c, g	8	1	8	3.7	29.6	1.48	2.96	$1,700.67
Review of no excess emissions report c, h	2	1	2	33.3	66.6	3.33	6.66	$3,826.50
Review of compliance deviations report d, j	8	1	8	1.2	9.6	0.48	0.96	$551.57
Review of no compliance deviations reports d, k	2	1	2	10.8	21.6	1.08	2.16	$1,241.03
TOTAL ANNUAL BURDEN AND COST l					581			$29,000
Assumptions:
a We have assumed that the average number of respondents that will be subject to the rule will be 44, which equates to 37 coating and printing sources, and 12 slashing, dyeing, and finishing sources. 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 cost is based on the following labor rates: Managerial rate of $69.04(GS-13, Step 5, $43.15 + 60%), Technical rate of $51.23 (GS-12, Step 1, $32.02 + 60%), and Clerical rate of $27.73 (GS-6, Step 3, $17.33 + 60%). These rates are from the Office of Personnel Management (OPM), 2021 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 This applies only to coating and printing facilities.
d This applies only to slashing, dyeing and finishing facilities.
e We have assumed that 10 percent of new sources will have to repeat performance test preparations and testing.
f Assume that 10 percent of new sources will review the repeat performance test report.
g We have assumed that 10 percent of respondents will be engaged in the reviewing of excess emissions reports.
h We have assumed that 90 percent of respondents will be engaged in the reviewing of no excess emissions reports.
i Facilities that comply with the 2019 amendment using emission capture systems and add-on controls will conduct air emissions performance testing, within 3 years of the effective date of the revised standards and no less frequently than once every five years thereafter. Labor totals include hours for the agency to travel to and from the facility to attend the test. Twenty add-on controls and would require periodic testing. The twenty does not include other lines also with add-on controls that are already required to periodically test because of state operating permit conditions. As these tests are conducted only once during the three-year period of this ICR, the number of occurrences per respondent per year is 0.33 (1/3=0.33). It is assumed that 5 percent of respondents will have to repeat performance tests.
j We have assumed that 10 percent of respondents will review the compliance deviations report.
k We have assumed that 90 percent of respondents will review the no compliance deviations report.
l Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: Capital 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)
Parametric monitoring (contractor)	$2,953	0	$0	$26	44	$1,144
Periodic performance Testing for Add-On Control a	$18,750	8	$150,000	$0	0	$0
Periodic performance Testing for Add-On Control b	$32,813	6	$196,875	$0	0	$0
Repeat of Periodic performance Testing for Add-On Control c	$18,750	1	$18,750	$0	0	$0
Total (rounded) d			$366,000			$1,140
Three-Year Average (rounded) d			$122,000			$1,140
a We estimated that 14 facilities using 20 control devices will perform periodic testing. During the three-year period of this ICR, 8 sources test one control device each at a cost of $18,750. Costs are based on the 2019 RTR (84 FR 9590).
b We estimated that 14 facilities using 20 control devices will perform periodic testing. During the three-year period of this ICR, 6 sources test two control devices each at a cost of $32,813. Costs are based on the 2019 RTR (84 FR 9590) and adjusted for an additional facility.
c We assumed 5% of tests will need to be repeated
d Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 4: Annual Responses

Total Annual Responses
(A)	(B)	(C)	(D)	(E)
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
Initial notification	0	1	0	0
Notification of construction/reconstruction	0	1	0	0
Notification of anticipated startup	0	1	0	0
Notification of actual startup	0	1	0	0
Notification of compliance status	0	1	0	0
Notification of performance test	0	1	0	0
Performance test report	0	1	0	0
Notification of performance test (add-on control)	21	0.33	0	6.9
Performance test report (add-on control)	21	0.33	0	6.9
Report of monitoring exceedances	3.7	2	0	7.4
Report of no excess emissions	33.3	2	0	66.6
Report of compliance deviation	1.2	2	0	2.4
Report of no compliance deviations	10.8	2	0	21.6
			Total (rounded)	112
			Hours Per Response	63.2