Burden Calculation Tables

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Overview

Industry
Agency
CAP&O&M

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Sheet 1: Industry

					122.2	153.55	61.51	Updated labor rates
Table 1: Annual Respondent Burden and Cost – NESHAP for Polyvinyl Chloride and Copolymers Production (40 CFR Part 63, Subpart HHHHHHH) (Renewal)
Burden Item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Respondent	Number of	Hours	Number of	Technical	Management	Clerical	Total
	Hours per	Occurrences	Per	Respondents	Hours	Hours	Hours	Labor Costs
	Occurrence	Per	Respondent	Per Year a	Per Year	Per Year	Per Year	Per Year b
	(Technical	Respondent	Per Year
	hours)	Per Year	(C=A x B)		(C x D)	(E x 0.05)	(E x 0.1)
1. Applications	N/A
2. Surveys and Studies	N/A
3. Reporting Requirements
A. Familiarization with Regulatory Requirements e,n
1) Existing respondents	8	1	8	13	104	5	10	$14,147
2) New respondents	320	1	320	0	0	0	0	$0
B. Required Activities
1) Initial performance test, sampling, and report
a) Process Vents c,e	120	1	120	0	0	0	0	$0
b) Resins c,g	36	1	36	0	0	0	0	$0
c) wastewater c,h	8	1	8	0	0	0	0	$0
d) uncontrolled wastewater c,h	40	1	40	0	0	0	0	$0
e) heat exchangers c,i	8	1	8	0	0	0	0	$0
f) equipment leaks c,j	850	1	850	0	0	0	0	$0
2) Periodic performance test, sampling, and report
a) Process Vents f	17.1	350	5985	13	77,805	3,890	7,781	$10,583,697.44
b) Resins g	36	362	13032	13	169,416	8,471	16,942	$23,045,404
c) wastewater h	8	12	96	13	1,248	62	125	$169,763.57
d) uncontrolled wastewater h	40	1	40	13	520	26	52	$70,734.82
e) heat exchangers i	8	12	96	13	1,248	62	125	$169,763.57
f) equipment leaks j	43	12	516	13	6,708	335	671	$912,479.18
3) Establish operating parameters and monitoring plan
a) Process Vents c,d,e	8	1	8	0	0	0	0	$0
4) Continuous parameter monitoring
a) Initial capital costs (PRD Electronic Monitor) c,ik	524	1	524	0	0	0	0	$0
b) Annualized PRD Electronic Monitor Review k	10	1	10	13	130	6.50	13.00	$17,683.71
5) Other requirements
a) equipment openings, initial measurement c,o	1.5	1	1.5	0	0	0	0	$0
b) equipment openings, daily measurement o	1.5	350	525	13	6,825	341.25	682.5	$928,395
c) gasholders p	1	1	1	12	12	0.6	1.2	$1,632
d) storage vessels q	2	1	2	13	26	1.3	2.6	$3,537
e) bypasses, initial requirement c,r	40	1	40	0	0	0	0	$0
f) bypasses, ongoing inspection r	2	12	24	13	312	15.6	31.2	$42,440.89
C. Create Information	Incl. in 3.B
D. Gather Information	Incl. in 3.E
E. Report Preparation
1) Initial Notification c,d	5	1	5	0	0	0	0	$0
2) Batch precompliance report c,d	5	1	5	0	0	0	0	$0
3) Notification of performance test with test plan c,d	10	1	10	0	0	0	0	$0
4) Notification of compliance status c,d	20	1	20	0	0	0	0	$0
5) Compliance report d,k	40	2	80	13	1,040	52	104	$141,469.64
6) Notice of inspection d	5	1	5	13	65	3	7	$8,841.85
Subtotal for Reporting Requirements m					305,278			$36,109,990
4. Recordkeeping Requirements
A. Familiarization with Regulatory Requirements	Incl. in 3.A
B. Implement Activities	N/A
C. Develop Record System	N/A
D. Record Information
1) Records of process vent requirements d	10	12	120	13	1,560	78	156	$212,204.46
2) Records of resin stripper requirements d	10	12	120	13	1,560	78	156	$212,204.46
3) Records wastewater requirements d	10	12	120	13	1,560	78	156	$212,204.46
4) Records of storage vessel requirements d	10	12	120	13	1,560	78	156	$212,204.46
5) Records of equipment leak requirements d	10	12	120	13	1,560	78	156	$212,204.46
6) Records of heat exchanger requirements d	10	12	120	13	1,560	78	156	$212,204.46
7) Records of other emission sources requirements d	10	12	120	13	1,560	78	156	$212,204.46
E. Personnel Training	Incl. in 3.B
F. Time for Audits	N/A
Subtotal for Recordkeeping Requirements					12,558			1,485,000		39
TOTAL LABOR BURDEN AND COSTS (rounded)s					318,000			37,600,000		8,154	hr per resp
TOTAL CAPITAL AND O&M COST (rounded)s								7,140,000
GRAND TOTAL (rounded)s								44,700,000
FOOTNOTES
aAssumes that, over the next three years, approximately 13 respondents per year will be subject to the standard, and no additional respondents per year will become subject to the standard.
bLabor rates are $153.55 for managerial, $122.20 for technical, and $61.51 for clerical. These rates 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 percent to account for the benefit packages available to those employed by private industry.
cOne-time only costs.
dCost incurred by a facility regardless of the number of affected units at the plant. Per VI's comments, this is performed monthly. We have assumed 10 hours per month for each process listed.
eThere are 13 major sources in the affected source category. The previous count of 15 major sources counted Formosa Point Comfort as two facilities; however, this ICR assumes this is a single facility due to shared equipment, controls, and/or employees. Additionally, the Vinyl Institute (VI) informed EPA that the Wacker Calvert city facility discontinued PVC operations. Therefore, the count of major source facilities is adjusted to 13.
f13 major sources are expected to perform testing for process vents. OxyVinyls Pedricktown does not operate a process vent control, but rather sends process vent gas streams to Mexichem Pedricktown for control. Per VI, it is assumed that performance testing for process vents will take 120 hours per occurrence initially. The initial compliance and operating procedure development for continuous compliance and will take 8 hours. The daily monitoring of parameters will take 5 min per record with 112 records a day across 32 devices in the industry. There are 3 area source and 13 major sources subject to this requirement. Therefore, the continuous/daily monitoring will take on avg 17.1 hr per facility per day over 350 day/yr.
gPer VI's previous comments, it is assumed that performance testing for resins will take 4 hours per sample for 9 samples per facility, initially and daily (350 days per year). Pursuant to 40 CFR 63.11960(d)(2), we have increased the number of occurrences from 350 to 362 to account for 12 monthly samples.
hPer VI, wastewater testing is estimated to take 4 hours per sample for 2 samples per facility. There are 13 wastewater streams for 13 major sources, yields 13/13 wastewater streams per major source that are sampled monthly. There are 5 uncontrolled wastewater streams per source that are sampled annually. See Capital/O&M costs for non-VC TOHAP samples.
iPer VI, it is assumed that performance testing on heat exchangers will take 4 hours per sample for 2 samples per facility, initially and monthly, for 16 of the 17 major sources. One of the sources relies on another facility to cool the water.
jFor Equipment leaks, VI estimates approx 10,000 components per facility and 5 minutes per component, plus additional time calibration of analytical device for a total of 850 hr per facility. For continuous monitoring, we assume 1 hr is required per component for leak repair, if detected. It was assumed that overall continuous compliace of leak monitoring will take 5% of the time with initial monitoring per month.
kThe Annualized PRD Electronic Monitor Review hours have been updated to include hours for corrective action for discharges and hours for replacement analysis. Per VI's comments, corrective action for discharge from a PRD would take 24 hours, and less than one PRD discharge event occurs per year in the entire industry. The number of hours for a discharge event is estimated to be 24/13 = 1.8 (rounded to 2) hours per facility. Per VI's comments, analysis for replacement of PRD monitors is estimated to take 24 hours per facility. Because the lifetime of a PRD monitor is expected to be 7 years, we do not expect the replacement analysis to occur annually, and we have assumed that this occurs once every 3 years (24 hrs/3 years = 8 hours per year).
lPer VI, Estimated that semiannual compliance reports would take 40 technical hours twice per year.
mReporting subtotal does not include capital costs for PRD monitoring system.
nBecause the rule requirements have not changed for existing respondents, we assume it will take 8 hours per respondent to read and understand the rule requirements (1 hr for 8 employees). We assume minimal time is needed each year to refamiliarize with rule requirements for existing employees. We assume that new employees will need 320 hours to familiarize with rule requirements (40 hours for 8 employees).
oFor Equipment openings, Per VI, 1.5 hr to obtain measurement, initially, daily.
pPer VI's previous comments, this will require 24 hrs to evaluate compliance options, order materials, monitor installation, and developing O&M procedures. Note: there are only 13 gas holders in the industry among major & area sources (12 at major sources and 1 at an area source). This is assumed to be a one-time cost. Per VI's comments, facilities are performing this annually. We have assumed that annual updates to compliance options, order materials, monitor installation, and O&M procedures will require 5% of the time that was needed to meet the initial requirements.
qPer VI's previous comments, 40 hrs per facility to develop initial and ongoing compliance, inspection,and maintenance plans and procedures. This is assumed to be a one-time cost. Per VI's comments, facilities are performing this annually. We have assumed that annual updates will require 5% of the time that was needed to meet the initial requirements.
rPer VI, 40 hrs per facility for traning, development, and implementation; and it will take 2 hrs per month to inspect car seals per facility.
sTotals 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 Polyvinyl Chloride and Copolymers Production (40 CFR Part 63, Subpart HHHHHHH) (Renewal)
				2021:	51.23	69.04	27.73		Increase: Update labor rates
	(A)	(B)	(C)	(D)	(E) Technical person-hours per year (E=CxD)	(F) Management person-hours per year (Ex0.05)	(G) Clerical person-hours per year (Ex0.10)	(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 a				EPA Cost Per Year b
1. Applications	not applicable
2. Familiarization with Rule Requirements	15	1	15	0	0	0	0	$0
3. Required Activities
A. Observe initial performance tests c	48	1	48	0	0	0	0	$0
B. Excess emissions -- Enforcement Activities d	24	1	24	1.3	31	2	3	$1,792.60
C. Create Information	not applicable
D. Gather Information	not applicable
E. Report Reviews
1) Review initial notification	3	1	3	0	0	0	0	$0
2) Review batch precompliance report	5	1	5	0	0	0	0	$0
3) Review notification of performance test	10	1	10	0	0	0	0	$0
4) Review notification of compliance status	40	1	40	0	0	0	0	$0
5) Review compliance report	20	2	40	13	520	26	52	$29,876.60
6) Review notice of inspection	3	1	3	13	39	2	4	$2,240.75
F. Prepare annual summary report e	4	1	4	6	24	1	2	$1,378.92
4. Travel expenses: (1 person * 30 hours per year / 8 hours per day * $75 per diem) + ($600 per round trip) =						n/a	per trip	$0
TOTAL ANNUAL BURDEN AND COST (rounded)f					706			$35,300
FOOTNOTES
aAssumes that, over the next three years, approximately 13 respondents per year will be subject to the standard, and no additional respondents per year will become subject to the standard.
bLabor rates are $69.04 for managerial (GS-13, Step 5, $43.15 + 60%), $51.23 for technical (GS-12, Step 1, $32.02 + 60%), and $27.73 for clerical (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.
cAssumes EPA personnel attend 20 percent of the initial process vent stack tests.
dAssume 10% of major source facilities (13) have emission exceedances.
eUsing four hours per state (6 states) to write annual summary report.
fTotals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: CAP&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)
Continuous Parameter Monitoring
PRD Electronic Monitor 8	$375,000	0	$0	$26,897	13	$349,661
VC Ambient monitoring 9				$207,692	13	$2,700,000
Gas holders	$5,000	0	$0
Periodic Testing
Process Vent Testing10	$51,198	0	$0	$99,080	32	$3,170,560
Resin Sampling and Monitoring 1	$1,803	0	$0	$7,200	13	$93,600
Stripped resin: Non-VC TOHAP testing 2	$1,950	0	$0	$23,400	13	$304,200
Wastewater Testing3	$491	0	$0	$5,892	13	$76,596
Wastewater: Non-VC TOHAP testing4	$650	0	$0	$7,800	13	$101,400
Uncontrolled Wastewater testing 5	$0	0	$0	$3,437	13	$44,681
Uncontrolled wastewater: Non-VC TOHAP testing 6	$3,250	0	$0	$4,550	13	$59,150
Equipment Leak Testing 7	$77,798	0	$0	$18,205	13	$236,665
Total
			$0			$7,140,000
1Per VI's comments, monthly maintenance and service of a lab GC costs $600 per unit.
2Per VI's previous comments, the costs of Non-VC TOHAP testing is $650 per sample, and 3 resin samples per facility.
3Monthly testing ($491 x 12 months = $5,892 per year)
4Per VI's previous comments, the costs of Non-VC TOHAP testing is $650 per sample, and one sample per facility.
5Per VI's comments, there are 5 uncontrolled wastewater streams and 2 cooling tower streams per source sampled annually. Using a cost of $491 per sample x 7 samples = $3,437
6The costs of Non-VC TOHAP testing is assumed to be $650 per sample. Per VI's comments there are 5 uncontrolled wastewater streams and 2 cooling water streams per source sampled annually. $650 x 7 = $4,550
713 facilities maintain LDAR programs to comply with 40 CFR 63, Subpart UU
8 The capital cost of a PRD monitor is $15,000 per device, and it is assumed that 25 devices per facility require indicators.
9 Per VI's comments, there are approximately 60 GC monitors at the 13 major sources in the industry with an annual O&M cost of $45,000 per monitor.
10 Per VI's comments, the cost to test one thermal oxidizer in 2018 was $99,080 and there are 32 thermal oxidizers in operation at 13 major source facilities