Burden Calculation Tables

1156t15.xlsx

NSPS for Synthetic Fiber Production Facilities (40 CFR Part 60, Subpart HHH) (Renewal)

Burden Calculation Tables

OMB: 2060-0059

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Overview

Table 1
Table 2


Sheet 1: Table 1

Table 1: Annual Respondent Burden and Cost – NSPS for Synthetic Fiber Production Facilities (40 CFR Part 60, Subpart HHH) (Renewal)






















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 (AxB) Respondents per yeara Technical person-hours per year (CxD) Management person-hours per year (Ex0.05) Clerical person-hours per year (Ex0.1) Cost, $b


1. Applications N/A







Labor Rates
2. Survey and Studies N/A







Management $153.55
3. Reporting Requirements








Technical $122.20
A. Familiarize with rule requirements 1 1 1 22 22 1.1 2.2 $2,992.63
Clerical $61.51
B. Required activities










Initial performance test 72 1 72 0 0 0 0 $0


Repeat performance test c 72 0.2 14.4 0 0 0 0 $0


C. Create information See 3B









D. Gather existing information See 3B









E. Write report










New Sources










Notification of construction/ reconstruction d 2 1 2 0 0 0 0 $0


Notification of actual startup d 2 1 2 0 0 0 0 $0


Notification of initial performance test d 2 1 2 0 0 0 0 $0


Notification of demonstration of CMS d 2 1 2 0 0 0 0 $0


Report of initial performance test d See 3B









Existing Sources










Quarterly report of VOCs emission exceedances e 8 0.5 4 22 88 4.4 8.8 $11,970.51


Semiannual report of no exceedances f 2 2 4 22 88 4.4 8.8 $11,970.51


Notification of limit exceedance for extruded fiber g 2 1 2 0 0 0 0 $0


Subtotal for Reporting Requirements



228 $26,934


4. Recordkeeping requirements










A. Familiarize with rule requirements See 3A









B. Plan activities See 4C









C. Implement activities See 3B









D. Develop record system See 4E








E. Time to enter information










Records of operating parameters h 0.25 250 62.5 22 1375 68.75 137.5 $187,039.19


Records of monthly VOC emission i 0.25 12 3 22 66 3.3 6.6 $8,977.88


F. Time to train personnel N/A









G. Time for audits N/A









Subtotal for Recordkeeping Requirements



1,657 $196,017


TOTAL LABOR BURDEN AND COST(roundedj)



1,880 $223,000
# Hours per response
Total CAPITAL AND O&M Costs (rounded)j






$165,000
34
Grand Total (rounded)j






$388,000














Assumptions:










a We have assumed that the average number of respondents that will be subject to the rule will be 22. There will be no additional new source 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 We have assumed that 20 percent of initial performance tests will be repeated.


d We have assumed that there will be no new sources over the three-year period of this ICR.


e We have assumed that each respondent will submit one quarterly report every other year due to excess of volatile organic compounds (VOCs) emissions.


f Semiannual reports are required of all respondents.


g We have assumed that there are no existing solvent-spun synthetic fiber producing facility subject to the exemption under section 60.600(a) that would have exceeded the annual requirement of 500 mg. Therefore, no existing solvent-spun synthetic fiber producing facility will submit a notification of exceeding the limits over the three-year period of the ICR.


h We have assumed that respondents will enter information on records of operating parameters 250 days per year.


i Respondents are required to conduct monthly calculation of the 6 months VOC average emission which is considered a performance test. Respondents will have to determine this value by calculating the VOC emissions per unit of mass solvent feed from each affected facility for the current and proceeding five consecutive calendar months.


j Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.



Sheet 2: Table 2

Table 2: Average Annual EPA Burden and Cost – NSPS for Synthetic Fiber Production Facilities (40 CFR Part 60, Subpart
HHH) (Renewal)















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 (AxB) Plants per yeara Technical person-hours per year (CxD) Management person-hours per year (Ex0.05) Clerical person-hours per year (Ex0.1) Cost, $b


Required Activities








Labor Rates
New Plant








Management $69.04
Initial performance test 24 1 24 0 0 0 0 $0
Technical $51.23
Repeat performance test c 24 0.2 4.8 0 0 0 0 $0
Clerical $27.73
Report review










New Plant










Notification of construction 2 1 2 0 0 0 0 $0


Notification of actual startup 0.5 1 0.5 0 0 0 0 $0


Notification of initial test 0.5 1.2 0.6 0 0 0 0 $0


Review test results 8 1.2 9.6 0 0 0 0 $0


Notification of demonstration of CMS 0.5 1 0.5 0 0 0 0 $0


Existing Plant










Quarterly report of VOCs emission exceedances d 2 0.5 1 22 22 1.1 2.2 $1,264.01


Semiannual report of no VOC emission exceedances e 2 2 4 22 88 4.4 8.8 $5,056.04


Notification of limit exceedance for extruded fiber 2 1 2 0 0 0 0 $0


TOTAL ANNUAL BURDEN AND COST (rounded) f



127 $6,320














Assumptions:










a We have assumed that the average number of respondents that will be subject to the rule will be 22. There will be no additional new source 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 which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: 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.


c We have assumed that 20 percent of initial performance tests will be repeated.


d We have assumed that each respondent will submit one quarterly report every other year due to excess of volatile organic compounds (VOCs) emissions.


e Semiannual reports are required of all respondents.


f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.


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