Burden Calculation Tables

---

Overview

Respondent
Agency
Capital and O&M
Additional

---

Sheet 1: Respondent

Table 1: Annual Respondent Burden and Cost – NESHAP for Chemical Manufacturing Area Sources (40 CFR Part 63, Subpart VVVVVV) (Renewal)
		A	B	C	D	E	F	G	H		TECH	122.2
	Burden Item	Hours per occurrence	No. of occurrences per respondent per year	Hours per respondent per year	Respondents per yeara	Technical hours per year	Management hours per year	Clerical hours per year	Total costs per year ($)b		MNG	153.55
				(C = A x B)		(E = C x D)	(F = E x 0.05)	(G = E x 0.10)			CLER	61.51
	1. APPLICATIONS	N/A									HR/RESP	15
	2. SURVEY AND STUDIES
	Heat exchange system monitoring planc	40	1	40	0	0	0	0	$0
	Metal process vent monitoring pland	30	1	30	1	30	1.5	3	$4,080.86
	3. REPORTING REQUIREMENTS
	A. Familiarize with Rule Requirement e	8	1	8	548	4,384.00	219.2	438.4	$596,348.94
	B. Required Activities
	Initial Performance testf	24	1	24	0.2	4.8	0.24	0.48	$652.94
	Design evaluation for process vent sourcesf	40	1	40	0.8	32	1.6	3.2	$4,352.91
	Repeat Performance testg	24	1	24	0	0	0	0	$0
	C. Create Information	Included in 3B
	D. Gather Existing Information	Included in 3E
	E. Write Report
	Notification of construction/reconstructionh	2	1	2	10	20	1.0	2.0	$2,720.57
	Initial notificationi	2	1	2	10	20	1.0	2.0	$2,720.57
	Notification of compliance statusj	8	1	8	10	80	4.0	8.0	$10,882.28
	Notification of initial performance testk	2	1	2	0.2	0.4	0.02	0.04	$54.41
	Report of performance test	Included in 3B
	Semiannual compliance reportsl	8	2	16	109.6	1,753.60	88	175	$238,539.58
	Reporting subtotal					7,273.52			$860,353.06
	4. RECORDKEEPING REQUIREMENTS
	A. Familiarize with Rule Requirementse	Included in 3A
	B. Plan Activities	Included in 3B
	C. Implement Activities
	Initial calculations and demonstrations
	TRE calculation for continuous process ventsm	3	1	3	1.50	4.50	0.23	0.45	$612.13
	Calculation of batch process vent emissionsn	6	1	6	4.50	27.0	1.35	2.70	$3,672.77
	Calculation of metal HAP emissionso	2	1	2	2	4	0.2	0.4	$544.11
	Capacity and MTVP calculations for storage tanksp	1	1	1	0	0	0	0	$0
	Inspection or seal gap measurement for storage tanksq	2	1	2	0	0	0	0	$0
	Determination of HAP concentrations in wastewater streamsr	20	1	20	3	60	3.0	6	$8,161.71
	Recurring calculations and tracking requirements
	Organic HAP batch process vent emissionss	0.5	12	6	4.50	27	1.35	2.7	$3,672.77
	Metal process vent emissionst	0.5	12	6	1	6	0.3	0.6	$816.17
	Quarterly CMPU management practice inspectionsu	3	4	12	0	0	0	0	$0
	D. Develop Record System	20	1	20	10	200	10	20	$27,205.70
	E. Time to Enter Information
	Operating parameters for control devices (batch and continuous process vents)v	0.25	52	13	23.2	302	15	30	$41,065.02
	Records of CMPU leak inspections	Included in 4C
	Records of heat exchange system monitoring	Included in 2
	Information related to bag leak detection systemsw	2	4	8	272	2,175.19	108.8	217.5	$295,887.49
	Records of inspections or seal gap measurements for storage tanks equipped with floating roofs	Included in 4C
	F. Train Personnel
	Initial	N/A
	Refresher and new personnel	N/A
	G. Audits	N/A
	Recordkeeping subtotal					3,226			$381,637.87
	TOTAL ANNUAL BURDEN x					10,500			$1,240,000
	Capital and O&M Cost (see Section 6(b)(iii)): x								$1,590,000
	TOTAL COST: x								$2,830,000
	Assumptions:
	a Over the next three years, approximately 538 existing respondents per year will be subject to the standard, and 10 additional respondents per year will become subject to the standard (assuming approximately 2 percent growth per year). Of these existing respondents (and new respondents), 271 have only organic HAP emissions (5 new respondents), 212 have only metal HAP emissions (4 new respondents), and 55 have both types of emissions (1 new respondent).
	b. This ICR uses the following labor rates: Technical $122.20 ($58.19 + 110%); Managerial $153.55 ($73.12+ 110%); and Clerical $61.51 ($29.29 + 110%). 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 percent to account for the benefit packages available to those employed by private industry. This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours.
	c We assume 80 percent of new sources with organic HAP emissions have heat exchange systems and will need to prepare a heat exchange system inspection or monitoring plan. However, this cost was included as part of the heat exchange system monitoring program cost.
	d All new sources with a chemical manufacturing process unit (CMPU) having uncontrolled metal HAP emissions exceeding 400 lb/yr must prepare a metal process vent monitoring plan. The generally available control technologies or management practices (GACT) analysis conducted for the NESHAP estimated there to be 27 existing sources meeting this criterion. We estimate that 1 new source per year will conduct this activity.
	e We assume all facilities will spend an average of 8 hours per facility to read and understand monitoring, recordkeeping, and reporting requirements.
	f Per footnote d, we estimate that 1 new source per year will have uncontrolled metal HAP emissions exceeding 400 lb/yr. Each new source must demonstrate compliance by conducting either a performance test or a design evaluation. Although a small percentage of new sources are expected to meet NESHAP emissions control requirements for process vents, we assume that none will be constructed over the 3-year period of this ICR. We also assume that source technical staff will spend 24 hours on performance tests or 40 hours on design evaluations, and that 20 percent of sources will conduct performance testing while the remaining 80 percent will opt for design evaluation instead.
	g We assume 20 percent of performance tests must be repeated. Per footnote f, we assume that only 1 new source per year having uncontrolled metal HAP emissions exceeding 400 lb/yr will become subject to the NESHAP, and that it will opt for design evaluation instead of performance testing. Therefore, this ICR does not estimate the cost for a repeat performance test.
	h All new sources must submit notification of construction/reconstruction.
	i All new sources must submit initial notification.
	j All new sources must submit notification of compliance status. We assume that none of these sources will elect to comply with the overlapping rule provisions, which means no stringency determinations will be conducted (such determinations could double the cost of preparing the notification).
	k We assume 2 hours per notification. Also, per footnote f, we assume that 20 percent of sources will conduct performance testing.
	l We assume 20 percent of sources will meet the conditions requiring submittal of a semiannual compliance report. Both existing and new sources must submit these reports.
	m We assume that 25 percent of new sources with organic HAP emissions have continuous process vents, and that each source must calculate the total resource effectiveness (TRE) index.
	n Assume 75 percent of new sources with organic HAP emissions must calculate the total emissions from batch process vents. We also assume that there are 25 steps per process and 1 batch process per facility, which corresponds to approximately 6 hours of effort per respondent.
	o We assume 2 new source per year with metal HAP emissions must calculate total metal HAP emissions.
	p Records of tank dimensions, capacity, and maximum true vapor pressure (MTVP) are required for all storage tanks requiring control. We also assume no storage tanks at new sources meet the thresholds for control over the 3-year period of this ICR.
	q We assume no storage tanks at new sources meet the thresholds for control over the 3-year period of this ICR.
	r We assume each source with organic HAP emissions has process wastewater and must determine HAP concentrations in each stream. We also assume that 50 percent of sources will use process knowledge to characterize HAP concentrations. The other 50 percent will use sampling and analysis, resulting in the incursion of capital costs but not labor costs. Capital costs are calculated separately in this ICR, see Section 6(b).
	s We assume that 75 percent of sources with organic HAP emissions have batch process vents. All organic HAP emissions sources with batch process vents, except those using control devices, must track emissions from batch process vents or HAP usage. However, only new sources must comply during the 3 years of this ICR. We assume that none of these new sources will use control devices.
	t All sources having uncontrolled metal HAP emissions must track those emissions from metal process vents or track HAP usage. However, only new sources must comply during the 3 years of this ICR. We estimate 1 new source per year.
	u Only new sources must comply over the 3-year period of this ICR. We assume all new sources would be performing the required inspections in the absence of the rule; therefore, no burden is incurred as a result of the NESHAP.
	v We estimate approximately 7% of sources of organic HAP emissions have continuous and batch process vents and are required to monitor operating parameters on control devices. We also assume that when operating parameters must be monitored, sources will collect the data automatically, so that the only burden will be 0.25 hours per week to review results and verify proper system operation.
	w All sources using a baghouse to control metal HAP emissions must keep records of bag leak detection systems. We estimate new and existing sources with metal HAP emissions use a baghouse system.
	x Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

---

Sheet 2: Agency

Table 2: Average Annual EPA Burden and Cost – NESHAP for Chemical Manufacturing Area Sources (40 CFR Part 63, Subpart VVVVVV) (Renewal)
		A	B	C	D	E	F	G	H		TECH	51.23
	Burden Item	EPA Hours per Occurrence	No. of occurrences per plant per year	EPA hours per plant per year	Plants per year	EPA technical hours per year	EPA managerial hours per year	EPA clerical hours per year	Total cost per yeara ($)		MNG	69.04
				(C = A x B)		(E = C x D)	(F = E x 0.05)	(G = E x 0.10)			CLER	27.73
	Attendance of Initial Performance Testb,c	24	1	24	0.2	5	0.24	0.48	$276
	Attendance of Repeat Performance Testsd	24	1	24	0	0	0	0	$0
	Report Review
	Notification of construction/reconstructione	2	1	2	10	20	1.0	2.0	$1,149.10
	Initial Notificatione	0.5	1	0.5	10	5.0	0.25	0.50	$287.28
	Notification of compliance statuse,f	2.5	1	2.5	10	25.0	1.25	2.50	$1,436.38
	Notification of initial testg	0.5	1	0.5	0.2	0	0	0	$5.75
	Review test resultsg	0.5	1	0.5	0.2	0	0	0	$5.75
	Semiannual compliance reportsh	2	2	4	109.6	438	21.9	44	$25,188.27
	Subtotal					567			$28,348.30
	Travel Expenses i								$130.00
	TOTAL ANNUAL BURDEN j					567			$28,500
	Assumptions:
	a This cost is based on the average hourly labor rate as follows: Technical $51.23 (GS-12, Step 1, $32.02 + 60%); Managerial $69.04 (GS-13, Step 5, $43.14 + 60%); and Clerical $27.73 (GS-6, Step 3, $17.33 + 60%). This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. These rates are from the 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.
	b All new sources with a chemical manufacturing process unit (CMPU) having uncontrolled metal HAP emissions exceeding 400 lb/yr must prepare a metal process vent monitoring plan. The generally available control technologies or management practices (GACT) analysis conducted for the NESHAP estimated there to be 27 existing sources meeting this criterion. We estimate that 1 new source per year will conduct this activity.
	c Per footnote b, we estimate that 1 new source per year will have uncontrolled metal HAP emissions exceeding 400 lb/yr. Each new source must demonstrate compliance by conducting either a performance test or a design evaluation. Although a small percentage of new sources are expected to meet NESHAP emissions control requirements for process vents, we assume that none will be constructed over the 3-year period of this ICR. We also assume that source technical staff will spend 24 hours on performance tests or 40 hours on design evaluations, and that 20 percent of sources will conduct performance testing while the remaining 80 percent will opt for design evaluation instead.
	d We assume 20 percent of performance tests must be repeated. Per footnote b, we assume that only 1 new source per year having uncontrolled metal HAP emissions exceeding 400 lb/yr will become subject to the NESHAP, and that it will opt for design evaluation instead of performance testing. Therefore, this ICR does not estimate the cost for a repeat performance test.
	e All new sources must submit notification of construction/reconstruction, initial notification, and notification of compliance status.
	f We assume that none of these sources will elect to comply with the overlapping rule provisions, which means no stringency determinations will be conducted (such determinations could double the cost of preparing the notification).
	g Per footnote c, we assume that 20 percent of sources will conduct performance testing.
	h We assume 20 percent of sources will meet the conditions requiring submittal of a semiannual compliance report. Both existing and new sources must submit these reports.
	i Travel Expenses = (1 person x 0.2 plants/year x 3 days/plant x $50 per diem) + ($500 round trip/plant x 0.2 plants/year) = $130/year.										130
	j Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

---

Sheet 3: Capital and 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)
	Metal process vent performance tests1,2	$8,740	0.2	$1,748
	Fabric filter for metal process vents1,2,3,4,5	$17,533	0.2	$3,507	$5,618	272	$1,528,096
	Batch process vent and continuous process vent performance tests6	$24,420	0	$0
	Temperature monitoring system for batch and continuous process vents7	$3,620	0	$0	$1,202	33	$39,666
	Initial wastewater sampling and analysis8	$3,370	3	$10,110
	Cooling water sampling and analysis9			$0			0$
	Total10			$15,400			$1,570,000		$1,590,000
	Assumptions:
	1 All new sources with a chemical manufacturing process unit (CMPU) having uncontrolled metal HAP emissions exceeding 400 lb/yr must prepare a metal process vent monitoring plan. The generally available control technologies or management practices (GACT) analysis conducted for the NESHAP estimated there to be 27 existing sources meeting this criterion. We estimate that 1 new source per year will conduct this activity.
	2 Per footnote 1, we estimate that 1 new source per year will have uncontrolled metal HAP emissions exceeding 400 lb/yr. Each new source must demonstrate compliance by conducting either a performance test or a design evaluation. We assume that 20 percent of sources will conduct performance testing while the remaining 80 percent will opt for design evaluation instead. Assumes average cost for a performance test using Method 5 is $8,740 per test.
	3 Assumes each source with a control device for metal process vents uses a fabric filter. Assumes total purchase and installation costs for a bag leak detection system is $17,533.
	4 We assume all metal HAP emissions sources will spend $1,219 per bag leak detection system per year. We estimate that each source also will spend $4,399 per year to operate and maintain these systems, assuming 36 hours per year and technical labor rate of $122.20 per hour (36 hr/yr x $122.20/hr = $4,399/yr, after rounding). The total annual O&M cost is $5,618 per source.					<-- adjust this value (in cell F6 above as well) according to updated technical rate
	5 We estimate all new and existing sources with metal HAP emissions use a baghouse system. This includes 212 existing and 4 new sources with only metal HAP emissions and 55 existing sources and 1 new source with both metal and organic HAP emissions, for a total of 262 sources.
	6 Assumes 33 sources have a temperature monitoring system for process vents, including 5 existing sources have with continuous process vents and, 28 existing sources have with batch process vents, and (we assume no new sources in the 3 years of this ICR have subject batch or continuous process vents). Assumes average cost for a performance test using Method 18 is $24,420.
	7Assumes a temperature monitoring system is needed for each control device used to control batch process vents or continuous process vents. Assumes the monitoring equipment cost is $3,620 per system.
	8We assume all sources with organic HAP emissions have process wastewater and must determine HAP concentrations in each stream. We also assume that 50 percent will use sampling and analysis, resulting in the incursion of capital costs. The other 50 percent of sources will use process knowledge to characterize HAP concentrations (i.e., no capital costs). Assuming an average of 2 streams per source and 1 sample per stream, we estimate a total cost of $3,370 per source (2 streams/source x 1 sample/stream x $435/sample + $125/hr x 20 hr/source = $3,370/source).
	9Assumes cost of sampling and analysis is part of the monitoring program cost.
	10 Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

---

Sheet 4: Additional

Number of Respondents (.08)
							<--Changes in this tab to update based on # of respondents from year 3 of prior ICR and to continue 10 new sources/year.
	(A)	(B)	(C)	(D)	(E)
Year	Number of New Respondents 1	Number of Existing Respondents	Number of Existing Respondents that keep records but do not submit reports	Number of Existing Respondents That Are Also New Respondents	Number of Respondents
					(E=A+B+C-D)
1	10	528	0	0	538
2	10	538	0	0	548
3	10	548	0	0	558
Average	10	538	0	0	548
Total Annual Responses									Number of Respondents by Emissions Type (.06)
									Emissions Type	Existing Respondents	New Respondents	Existing & New
(A)	(B)	(C)	(D)	(E)					Only Organic HAP	246	5.2	251
Information Collection Activity	Number of Respondents	Number of Responses	Number of Existing Respondents That Keep Records But Do Not Submit Reports	Total Annual Responses					Only Metal HAP	193	4.1	197
				E=(BxC)+D					Both HAP	50	1.1	51
Notification of construction/reconstruction	10	1	0	10					Total	489	10	499
Initial notification	10	1	0	10
Notification of compliance status	10	1	0	10					Number of Respondents by Emissions Type (.07)
Notification of initial performance test	0.2	1	0	0.2					Emissions Type	Existing Respondents	New Respondents	Existing & New
Semiannual compliance report	109.6	2	430.4	649.6					Only Organic HAP	261	5.2	266
			Total	679.8					Only Metal HAP	204	4.1	208
									Both HAP	53	1.1	54
									Total	518	10	528
HAP Type Breakout									Number of Respondents by Emissions Type (.08)
ICR Renewal	Existing Respondents	Only Organic HAP	Only metal HAP	Both					Emissions Type	Existing Respondents	New Respondents	Existing & New
.04	512	258	202	52					Only Organic HAP	271	5	276
.05	452	228	178	46					Only Metal HAP	212	4	216
.05 Calc		228	178	46	0.8828125				Both HAP	55	1	56
.06 Calc	489	246	193	50	0.954382552083333				Total	538	10	548
.07 Calc	518	261	204	53
.08 Calc	538	271	212	55	1.05078125
Assuming 10 new sources per year:
New Sources for .08	10	5	4	1
		0.50	0.39	0.10