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	Increase:Updated labor rates
Table 1: Annual Respondent Burden and Cost – NESHAP for Polyvinyl Chloride and Copolymers Production Area Sources (40 CFR Part 63, Subpart DDDDDD) (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
		Respondent	Per Year
		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
New sources c,d,l	320	1	320	0	0	0	0	$0
Existing sources e	8	1	8	3	24	1.2	2.4	$3,264.68
B. Required Activities
1) Initial performance test, sampling, and report
a) Process Ventsc,f	120	1	120	0	0	0	0	$0
b) Resinsc,g	36	1	36	0	0	0	0	$0
c) wastewaterc,h	8	1	8	0	0	0	0	$0
d) uncontrolled wastewaterh	40	1	40	0	0	0	0	$0
e) heat exchangersi	8	1	8	0	0	0	0	$0
f) equipment leaksj	850	1	850	0	0	0	0	$0
2) Periodic performance test, sampling, and report
a) Process Ventsf	17.1	350	5,985	3	17,955	897.75	1,795.50	$2,442,391.72
b) Resinsg	36	362	13,032	3	39,096	1,955	3,910	$5,318,170.24
c) wastewaterh	8	12	96	3	288	14.4	28.8	$39,176.21
d) uncontrolled wastewaterh	40	1	40	3	120	6	12	$16,323.42
e) heat exchangersi	8	12	96	3	288	14.4	28.8	$39,176.21
f) equipment leaksj	43	12	510	3	1,530	76.5	153	$208,123.61
3) Establish operating parameters and monitoring plan
a) Process Ventsc,d,f	8	1	8	0	0	0	0	$0
4) Continuous parameter monitoring
a) Initial capital costs (PRD Electronic Monitor)c,k	524	1	524	0	0	0	0	$0
b) Annualized PRD Electronic Monitor Review k	10	1	10	3	30	1.5	3	$4,080.86
5) Other requirements
a) equipment openings, initial measurement m	1.5	1	1.5	0	0	0	0	$0
b) equipment openings, daily measurement m	1.5	350	525	3	1,575	78.75	157.5	$214,244.89
c) gasholders p	1	1	1	1	1	0	0	$136
d) storage vessels q	2	1	2	3	6	0	1	$816
e) bypasses, initial requirement m	40	1	40	0	0	0	0	$0
f) bypasses, ongoing inspection m,o	2	12	24	3	72	3.6	7	$9,794.05
C. Create Information	See 3.B
D. Gather Information	See 3.E
E. Report Preparation
1) Initial Notificationc,d	5	1	5	0	0	0	0	$0
2) Batch precompliance reportc,d	5	1	5	0	0	0	0	$0
3) Notification of performance test with test planc,d	10	1	10	0	0	0	0	$0
4) Notification of compliance statusc,d	20	1	20	0	0	0	0	$0
5) Compliance reportd	40	2	80	3	240	12	24	$32,646.84
6) Notice of inspectiond	5	1	5	3	15	0.75	1.5	$2,040.43
Reporting Subtotal					70,426			$8,330,385.34
4. Recordkeeping Requirements
A. Familiarization with Regulatory Requirements	See 3.A
B. Implement Activities	N/A
C. Develop Record System	N/A
D. Record Information
1) Records of process vent requirementsd	10	12	120	3	360	18	36	$48,970.26
2) Records of resin stripper requirementsd	10	12	120	3	360	18	36	$48,970.26
3) Records of wastewater requirementsd	10	12	120	3	360	18	36	$48,970.26
4) Records of storage vessel requirementsd	10	12	120	3	360	18	36	$48,970.26
5) Records of equipment leak requirementsd	10	12	120	3	360	18	36	$48,970.26
6) Records of heat exchanger requirementsd	10	12	120	3	360	18	36	$48,970.26
7) Records of other emission sources requirements	10	12	120	3	360	18	36	$48,970.26
E. Personnel Training	See 3.B
F. Time for Audits	N/A
Recordkeeping Subtotal					2,898			$342,791.82
TOTAL LABOR BURDEN AND COSTS (rounded):n					73,300			$8,670,000
TOTAL CAPITAL AND O&M COSTS (rounded): n								$1,000,000
GRAND TOTAL (rounded): n								$9,670,000	8144	hrs/response
a Assumes that, over the next three years, approximately 3 respondents per year will be subject to the standard, and no additional respondents per year will become subject to the standard.
b Labor 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.
c Costs apply only to newly-applicable sources.
d Cost 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.
e There are 3 area sources in the affected source category.
f 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 on avg 17.1 hr per facility per day over 350 day/yr.
g Per 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 63.11142(f)(16) and 63.11960(d)(2), we have increased the number of occurrences from 350 to 362 to account for 12 monthly samples.
h Estimated 1 uncontrolled stream and 1 wastewater stripper per facility. 1 wastewater stripper outlet is expected to require monthly testing; 5 uncontrolled stream will require annual testing (per facility). It will take 4 hours per sample for 2 samples per stream.
i It is assumed that performance testing on heat exchangers will take 4 hours per sample for 2 samples per facility, initially and monthly.
j For Equipment leaks, we estimate 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.
k The Annualized PRD Electronic Monitor Review hours have been updated to include hours for corrective action for dishcarges 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 alaysis to occur annually, and we have assumed that this occurs once every 3 years (24 hrs/3 years = 8 hours per year).
l Because 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).
m We have included this item based on comments previously provided by the Vinyl Institute.
n Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
o Per VI, 40 hrs per facility for traning, development, and implementation; and it will take 2 hrs per month to inspect car seals per facility.
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 is only gasholder 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.

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Sheet 2: Agency

				2021	51.23	69.04	27.73		Increase: Update labor rates
Table 2: Average Annual EPA Burden and Cost – NESHAP for Polyvinyl Chloride and Copolymers Production Area Sources (40 CFR Part 63, Subpart DDDDDD) (Renewal)
Burden Item	(A) EPA person-hours per occurrence	(B) No. of occurrences per plant per year	(C) EPA person-hours per plant per year (C=AxB)	(D) Plants 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 (Ex0.10)	(H) EPA Cost Per Year b
1. Applications	not applicable
2. Familiarize with Rule Requirements	16	0	0	0	0	0	0	$0
3. Required Activities
A. Observe initial performance testsc	48	0	0	0	0	0	0	$0
B. Excess emissions -- Enforcement Activitiesd	24	0	0	0	0	0	0	$0
C. Create Information	not applicable
D. Gather Information	not applicable
E. Report Reviews
1) Review initial notification	3	0	0	0	0	0	0	$0
2) Review batch precompliance report	5	0	0	0	0	0	0	$0
3) Review notification of performance test	10	0	0	0	0	0	0	$0
4) Review notification of compliance status	40	0	0	0	0	0	0	$0
5) Review compliance report	20	2	40	3	120	6	12	$6,894.60
6) Review notice of inspection	3	1	3	3	9	0.45	0.9	$517.10
F. Prepare annual summary reporte	4	1	4	3	12	0.6	1.2	$689.46
TOTAL (rounded) f					162			$8,100
a Assumes that, over the next three years, approximately 3 respondents per year will be subject to the standard, and no additional respondents per year will become subject to the standard.
b Labor 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.
c Assumes EPA personnel attend 20 percent of the initial process vent stack tests.
d Assumes no emissions exceedances.
e Assumes four hours per state to write annual summary report.
f Totals 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 Monitor3	$375,000	0	$0	$31,772	3	$95,316
VC Ambient monitoring 6				$135,000	3	$405,000
Gas holders	$5,000	0	$0
Periodic Testing
Process Vent Testing	$43,198	0	$0	$99,080	3	$297,240
Resin Sampling and Monitoring1	$1,803	0	$0	$7,200	3	$21,600
Resin: Non-VC TOHAP testing4	$1,950	0	$0	$23,400	3	$70,200
Wastewater Testing2	$491	0	$0	$5,892	3	$17,676
Wastewater Testing: Non-VC TOHAP testing	$650	0	$0	$7,800	3	$23,400
Uncontrolled Wastewater testing7	$0	0	$0	$3,437	3	$10,311
Uncontrolled Wastewater testing: Non-VC TOHAP testing 5	$3,250	0	$0	$4,550	3	$13,650
Equipment Leak Testing	$177,360	0	$0	$16,105	3	$48,315
Total8
			$0			$1,000,000
1 Per VI's comments, monthly maintenance and service of a lab GC costs $600 per unit.
2 Monthly testing ($491 x 12 months = $5,892 per year)
3 The capital cost of a PRD monitor is $15,000 per device, and it is assumed that 25 devices per facility require indicators.
4 The costs of Non-VC TOHAP testing is $650 per sample, and three samples per facility.
5 The 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
6 Per VI's comments, assume an average of 3 GC monitors per facility with an annual cost of $45,000 per monitor for vinyl chloride. The average annual O&M cost per facility is $135,000.
7Per 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
8Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.