Burden Tables

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Overview

Table 1
Table 2
Capital O&M

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Sheet 1: Table 1

Table 1: Annual Respondent Burden and Cost – NESHAP for Paper and Other Web Coating (40 CFR Part 63, Subpart JJJJ) (Renewal)
Burden Item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical person- hours per year (E=CxD)	(F) Management person hours per year (Ex0.05)	(G) Clerical person hours per year (Ex0.1)	(H) Cost, $ b
1. Reporting requirements										Labor Rates
A. Familiarization with regulatory requirements	8	1	8	171	1,368	68	137	$186,086.99		Management	$153.55
B. Gather information c	4	4	16	1	16	0.8	1.6	$2,176.46		Technical	$122.20
C. Initial performance testing (new sources) c										Clerical	$61.51
i. Initial notification	2	1	2	1	2	0.1	0.2	$272.06
ii. Notification of performance test	2	1	2	1	2	0.1	0.2	$272.06
iii. Notification of compliance status	2	1	2	1	2	0.1	0.2	$272.06
iv. Performance test report	2	1	2	1	2	0.1	0.2	$272.06
v. CMS performance evaluation	2	1	2	1	2	0.1	0.2	$272.06
D. Periodic performance testing d
i. Notification of test - thermal oxidizers	24	1	24	21	504	25	50	$68,558.36
ii. Attend test - thermal oxidizers	10	1	10	21	210	10.5	21	$28,565.99
iii. CMS performance evaluation - thermal oxidizers	2	1	2	21	42	2.1	4.2	$5,713.20
iv. Annual catalyst test - catalytic oxidizers	2	1	2	3	6	0.3	0.6	$816.17
E. Write reports
Semiannual summary report	4	2	8	171	1,368	68.4	136.8	$186,086.99
Subtotal for Reporting Requirements					4,053			$479,364
2. Recordkeeping requirements
A. Read instructions c	4	1	4	1	4	0.2	0.4	$544.11
B. Plan activities c	15	1	15	1	15	0.75	1.5	$2,040.43
C. Implement activities for compliance coating use e	5	12	60	80	4,800	240	480	$652,936.80
D. Implement activities for control devices and process equipment c
i. Design analysis	12	1	12	1	12	0.6	1.2	$1,632.34
ii. Performance test oversight	20	1	20	1	20	1	2	$2,720.57
E. Develop record system
ii. Develop plan for material used e	10	1	10	80	800	40	80	$108,822.80
iii. Control equipment and maintenance plan c	10	1	10	1	10	0.5	1	$1,360.29
F. Time to enter information
i. Compliance calculation e	2	12	24	80	1,920	96	192	$261,174.72
ii. Control equipment testing f	1	1	1	91	91	4.55	9.1	$12,378.59
iii. Records of failures to meet standards/actions taken to minimize emissions g	2	12	24	9	216	10.8	21.6	$29,382.16
G. Time to train personnel
i. Acquisition and installation c	15	1	15	1	15	0.75	1.5	$2,040.43
ii. Equipment inspection and monitoring f	10	1	10	91	910	45.5	91	$123,785.94
iii. Use of technology and systems	10	1	10	171	1,710	85.5	171	$232,608.74
H. Store, file and maintain records h	0.25	12	3	171	513	25.7	51.3	$69,782.62
I. Retrieve records/reports h	0.25	12	3	171	513	25.7	51.3	$69,782.62
Subtotal for Recordkeeping Requirements					13,281			$1,570,993		44	hr/response
Total Labor Burden and Costs (rounded) i					17,300			$2,050,000
Total Capital and O&M Cost (rounded) i								$975,000
GRAND TOTAL (rounded) i								$3,030,000
Assumptions:
a We assume that an average of 171 respondents (170 existing, 1 new) will be subject to this rule. We assume that one new source each year will become subject to the rule over the three-year period of the ICR.
b This ICR uses the following labor rates: Managerial $153.55 ($73.12+ 110%); Technical $122.20 ($58.19 + 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.
c We assume that new sources will use a solvent recovery device as an add-on control device to comply with the rule. This is a one-time activity for a new facility using a solvent recovery device. Sources using solvent recovery and CEMS or CMS to comply with the rule are required to perform initial performance testing.
d Based on review of permit data for ICR 1951.09, we estimate that an average of 90 facilities currently use add on control equipment and 80 facilities comply with the rule through the use of compliant coatings. Some permits already require periodic testing for control equipment. Periodic emissions performance testing will be required under this rule for 62 thermal oxidizers. Assume one-third are tested each year (62/3 = 21 per year). CMS performance is evaluated during the control device performance test for the thermal oxidizers. Annual catalyst testing will be required for 3 catalytic oxidizers.
e Based on permit data, we assume that 80 sources comply with the rule through the use of compliant coatings and will record activities for compliant coating use.
f We have estimated that 90 facilities currently use add on control equipment. Assuming each new facility added uses add-on control equipment, we assumed an average of 91 facilities per year with add on controls over the 3-year period.
g We have assumed that 5% of respondents will fail to meet standards each year (0.05 x 171 = 8.6, rounded to 9).
h We have assumed that 171 respondents will be involved in the storage, filing, maintenance and retrieval of records and reports twelve times per year.
i 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 Paper and Other Web Coating (40 CFR Part 63, Subpart JJJJ) (Renewal)
Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical person- hours per year (E=CxD)	(F) Management person hours per year (Ex0.05)	(G) Clerical person hours per year (Ex0.1)	(H) Cost, $ b
A. New Sources										Labor Rates
1. Review initial notification c	8	1	8	1	8	0.4	0.8	$459.64		Management	$69.04
2. Review notification of performance test d	2	1	2	1	2	0.1	0.2	$115		Technical	$51.23
3. Review notification of compliance status c	10	1	10	1	10	0.5	1	$574.55		Clerical	$27.73
4. Review performance test report and CMS performance evaluation c, d	10	1	10	1	10	0.5	1	$574.55
B. Periodic Testing
1. Review notification of periodic performance test and CMS performance evaluation e	4	1	4	21	84	4.2	8	$4,826.22
2. Review periodic performance test and CMS performance evaluation results e, f	10	1	10	21	210	10.5	21	$12,065.55
C. Semiannual summary report g	15	2	30	171	5,130	257	513	$294,744.15
TOTAL (rounded) h					6,270			$313,000
Assumptions:
a We assume that an average of 171 respondents (170 existing, 1 new) will be subject to this rule, and that one new source will become subject to the rule each year over the three-year period of the ICR.
b This cost is based on the average hourly labor rate as follows: Managerial $69.04 (GS-13, Step 5, $43.15 + 60%); Technical $51.23 (GS-12, Step 1, $32.02 + 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 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 We have assumed that this is a one-time activity for each new facility. We assume that new sources will use a solvent recovery device as an add-on control device to comply with the rule.
d Sources using solvent recovery and CEMS or CMS to comply with the rule are required to do initial performance testing.
e A total of 62 thermal oxidizers will have periodic emissions performance testing requirements and CMS performance evaluations. We assume one-third of thermal oxidizers will be tested each year (62/3 = 21, rounded).
f We assume that it will take the agency ten hours to review test results.
g We assume that it will take the agency 15 hours to review the semiannual reports and that the agency will review summary reports twice per year.
h 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

Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
	(A)	(B)	(C)	(D)	(E)
Year	Number of New Respondents a	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	1	169	0	0	170
2	1	170	0	0	171
3	1	171	0	0	172
Average	1	170	0	0	171
a New respondents include sources with constructed and reconstructed affected facilities.
Total Annual Responses
(A)	(B)	(C)	(D)	(E)
Information Collection Activity	Number of Respondents a	Number of Responses	Number of Existing Respondents That Keep Records But Do Not Submit Reports	Total Annual Responses E=(BxC)+D
Initial Notification	1	1	0	1
Notification of performance test	1	1	0	1
Notification of compliance status	1	1	0	1
Performance test reports	1	1	0	1
CMS performance evaluation	1	1	0	1
Periodic Emissions Testing of Thermal Oxidizers	21	1	0	21
Annual Catalyst Testing of Catalytic Oxidizers	3	1	0	3
CMS Performance Evaluation b	21	1	0	21
Semiannual report	171	2	0	342
			Total	392
a Based on permits examined for the recent final rule, we assume that an average of 90 facilities use add-on controls, with a total of 123 oxidizers and 18 carbon adsorbers. Some permits already require periodic testing. We estimate that an additional 65 oxidizers (62 thermal oxidizers and 3 catalytic oxidizers) will have to perform repeat testing under the rule. We assume one-third of the thermal ozidizers are tested each year (62/3 = 21, rounded). Three additional catalytic oxidizers will have to perform annual catalyst testing, in lieu of emissions testing.
b CMS performance is evaluated when a control device is tested. We assume 21 existing thermal oxidizers will be tested each year.
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 a	Total Capital/Startup Cost, (B X C)	Annual O&M Costs for One Respondent	Number of Respondents with O&M b	Total O&M, (E X F)
Initial performance test (inlet/outlet)	$28,000	1	$28,000
Parametric/continuous monitoring system (CMS)	$10,000	1	$10,000	$25	84	$2,100
Continuous emission monitoring system (CEMS)	$183,500	1	$183,500	$26,700	6	$160,200
Repeat emissions performance test - Thermal Oxidizers	$28,000	21	$588,000
Annual Catalyst Activity Testing - Catalytic Oxidizers				$1,000	3	$3,000
Totals (rounded) c			$810,000			$165,000		$975,000
a We estimate that one new facility using solvent recovery (carbon adsorption) and CEMs or CMS will be constructed each year. A facility using solvent recovery and CEMS or CMS requires initial testing. Thermal oxidizers require testing, and 62 of the 123 thermal oxidizers do not already have a testing requirement in their permit. We assume 21 (62/3 = 21, rounded) thermal oxidizers will perform periodic testing every year.
b We estimate an average of 171 sources (170 existing, 1 new) during the three-year period of this ICR. Permit data indicates that an average of 90 facilities use add-on controls (79 use oxidizers and 11 use carbon adsorption). All of the oxidizers use parametric monitoring (CMS), and it was assumed that 5 of the facilities using carbon adsorption do as well. The remaining 6 facilities using carbon adsorption were assumed to use CEMs. Three catalytic oxidizers do not already have a testing requirement in their permit and will comply by having the catalyst activity tested every year.
c Totals have been rounded to 3 significant digits. Figures may not add exactly due to rounding.