Burden Calculation Tables

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Overview

Summary
Table 1
Table 2
Capital O&M
Responses
Respondents

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Sheet 1: Summary

ICR Summary Information
Hours per Response	338
Number of Respondents	19
Total Estimated Burden Hours	56,400
Total Estimated Costs	$12,000,000
Annualized Capital O&M	$5,230,000
Total Annual Responses	167
Form Number	Not Applicable

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Sheet 2: Table 1

Table 1: Annual Respondent Burden and Cost – NESHAP for Group I Polymers and Resins (40 CFR Part 63, Subpart U) (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 (C=AxB)	Respondents per year a	Technical person- hours per year (E=CxD)	Management person-hours per year (F=Ex0.05)	Clerical person-hours per year (G=Ex0.1)	Total Cost ($) b
1. Applications	N/A									Labor Rates:
2. Survey and Studies	N/A									Management	$157.61
3. Acquisition, Installation, and Utilization of Tech. and Systems	See 5F									Technical	$123.94
4. Reporting requirements										Clerical	$62.52
A. Familiarize with regulatory requirements c	64	1	64	19	1,216	60.8	121.6	$167,896.16	Old ICR, which is based on a the HON but with slightly reduced values as there are fewer reqs for this Subpart than the HON
B. Required activities d	6.08	13	79	19	1,501	75.1	150.1	$207,246.82	HON NESHAP - Old ICR said this Subpart has fewer reqs than the HON; however, the burden in the old ICR was higher than the estimate in the most recent HON ICR. Therefore, I used the HON estimate
C. Create Information d	18.06	80	1,445	19	27,455	1,372.75	2,745.5	$3,790,780.49	Old ICR, which is based on a the HON but with slightly reduced values as there are fewer reqs for this Subpart than the HON
D. Gather existing information d	2.33	300	699	19	13,281	664.05	1,328.1	$1,833,740.87	Old ICR, which is based on a the HON but with slightly reduced values as there are fewer reqs for this Subpart than the HON
E. Write report
Application of construction or reconstruction	2	1	2	0	0	0	0	$0	2 hrs is common for this notification
Request for extension of compliance	2	1	2	0	0	0	0	$0	assumed 2 hrs
Notification that source is subject to special compliance requirements	5	1	5	0	0	0	0	$0	hrs based on 7H 'initial" notification, no new respondents
Notification of compliance status	20	1	20	0	0	0	0	$0	hrs based on 7H, no new respondents
Notification of storage vessel inspection e	5	6	30	19	570	28.5	57	$78,701	hrs based on 7H, I assumed bimonthly storage vessel emptying and degassing
Notification of front-end process vents limit f	4	1	4	0	0	0	0	$0	per 2011 amendment
Notification of back-end process vents limit f	4	1	4	0	0	0	0	$0	per 2011 amendment
Progress reports for source receiving extension of compliance g	4	2	8	0	0	0	0	$0	hrs based on III, I assumed all existing sources are in compliance, new sources cannot get extensions.
Waiver of recordkeeping or reporting requirements	4	1	4	0	0	0	0	$0	assumed 4 hrs
Supplemental report for failing to submit information required to be included in reports h	2	1	2	0	0	0	0	$0	assumed 2 hrs
Operating permit application	40	1	40	0	0	0	0	$0	Operating permit has similar requirements to precompliance report so I assumed the hrs were the same.
Precompliance report i	40	1	40	0	0	0	0	$0	hrs based on 7H, no new respondents
Emissions averaging plan j	120	1	120	0	0	0	0	$0	hrs based on 4D (note Subpart 4D is not necessarily related to this rule, but the other polymer rules did no include emissions averaging plans), I assumed 10% existing respondents use EA, new respondents not allowed to use EA
Updates to emissions averaging plan k	20	1	20	1	20	1	2	$2,761	hrs assumed. I also assumed 1 facility per year will make a change necessitating an update to the EA plan.
Request for approval for a nominal control efficiency for use in calculating credits for emission averaging j	2	1	2	0	0	0	0	$0	hrs based on 4D (note Subpart 4D is not necessarily related to this rule, but the other polymer rules did no include emissions averaging plans), I assumed 10% existing respondents use EA and no sources using EA will request approval for nominal control efficiency after submitting the initial plan, new respondents not allowed to use EA.
Semiannual periodic reports l	80	2	160	16	2,560	128	256	$353,466	hrs from HON NESHAP
Quarterly periodic reports for facilities using emission averaging and where a respondent did not qualify for semiannual reporting l	80	4	320	3	960	48	96	$132,550	10% for EA + 5% of other sources (assumed) - hrs same as semiannual
Compliance redetermination report for back-end process operations using a control or recovery device m	20	1	20	2	40	2	4	$5,523	I assumed 10% make changes require redetermination of compliance
Report of changes to the primary product for an EPPU or process unit n	2	1	2	2	4	0.2	0.4	$552	hrs based on PPP "phys/operational change", I assumed 10% will make change
Report of changes or additions to plant sites o	2	1	2	0	0	0	0	$0	hrs based on PPP "phys/operational change", I assumed no respondents will make a change or addition
Malfunction report p	8	2	16	2	32	1.6	3.2	$4,418	8 hrs and 10% of sources is common for malfunction reports
Subtotal for Reporting Requirements					54,785			$6,577,636
5. Recordkeeping requirements
A. Familiarize with regulatory requirements	See 4A
B. Plan activities	See 4B
C. Implement activities	See 4B
D. Develop record system	See 5E
E. Time to enter information
Plan activities	See 4B
Create, test, research, develop	See 4C
Gather information, monitor, inspect	See 4D
Process, compile, review d	20	1	20	19	380	19	38	$52,467.55	HON NESHAP - see footnote d (Old ICR said this Subpart has fewer reqs than the HON; however, the burden in the old ICR was higher than the estimate in the most recent HON ICR. Therefore, I used the HON estimate)
F. Train personnel d	2.1	10	21	19	399	19.95	39.9	$55,090.93	HON NESHAP - see footnote d (Old ICR said this Subpart has fewer reqs than the HON; however, the burden in the old ICR was higher than the estimate in the most recent HON ICR. Therefore, I used the HON estimate)
G. Adjust existing ways to comply with prev. appl. reg.	N/A
H. Record and disclose information d	10.5	2	21	19	399	19.95	39.9	$55,090.93	Old ICR, which is based on a the HON but with reduced values as there are fewer reqs for this Subpart than the HON
Store, file and maintain records	1	12	12	19	228	11.4	22.8	$31,480.53	From amendment, but assuming all facilities have this requirement
I. Audits	N/A
Subtotal for Recordkeeping					1,617			$194,130		responses	hr/response
TOTAL ANNUAL BURDEN AND COST (rounded) q					56,400			$6,770,000		167	338
CAPITAL AND O&M COST (rounded) q								$5,230,000
GRAND TOTAL (rounded) q								$12,000,000
Assumptions:
a We assume there are 19 existing sources subject to the standard and no additional sources per year will be become subject to the standard during the three-year period of this ICR
b This ICR uses the following labor rates: $157.61 per hour for Executive, Administrative, and Managerial labor; $123.94 per hour for Technical labor, and $62.52 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 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 varying industry wage rates and the additional overhead business costs of employing workers beyond their wages and benefits, including business expenses associated with hiring, training, and equipping their employees.
c This ICR assumes all existing sources will have to familiarize with the regulatory requirements each year.
d The burden for these activities are based on similar requirements in the HON NESHAP (Subparts F, G, H, and I). The HON NESHAP indicates that the activities within each burden category (i.e., process vents, equipment leaks, wastewater, heat exchangers, and equipment leaks) can vary significantly; therefore, it is too inaccurate to assume an average activity time (Column A) to calculate hours per facility (Column C). Rather, the HON NESHAP estimates the total hours per facility, estimates the number activities per year (Column B) and uses the two numbers to back-calculate Column A. The HON NESHAP also notes that the number of activities per year may vary from facility to facility, depending on consolidation of activities, collocated readings, etc. Since so much variability exists, it is important to note that this is an estimate and is only used to back-calculate Column A.
e This ICR assumes that each facility will refill storage vessels that have been emptied and degassed 6 times per year.
f This ICR assumes that notifications for front- and back-end limits are submitted during the initial compliance period.
g This ICR assumes that all existing sources are already in compliance; new sources cannot receive compliance extensions.
h This ICR assumes no respondents will be required to submit supplemental reports.
i This ICR assumes that 10% of new sources will submit precompliance reports.
j This ICR assume 10% of existing facilities will elect to use emission averaging and that all existing respondents are already in compliance; new facilities cannot use emissions averaging. This ICR also assumes no existing facilities will elect to use nominal control after submitting the initial emissions averaging plan.
k This ICR assumes 1 facility per year using an emissions averaging plan will make changes requiring an update to the emissions averaging plan.
l This ICR assumes that 5% of sources will not qualify for semiannual reports and will be required to submit quarterly reports. In addition, the 10% of facilities using emissions averaging are required to submit quarterly reports [(10% x 19) + (5% x 19)= 2.85 sources, rounded to 3]. The remaining 16 sources will all submit semiannual reports.
m This ICR assumes 10% of sources will make a process change that will require a redetermination of compliance report.
n This ICR assumes that 10% of sources will have changes to their primary product.
o This ICR assumes that no respondents will make changes or additions to the plant sites.
p This ICR assumes that 10% of sources will have to submit malfunction reports.
q Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: Table 2

Table 2: Average Annual EPA Burden and Cost – NESHAP for Group I Polymers and Resins (40 CFR Part 63, Subpart U) (Renewal)
Burden Item	(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 (C=AxB)	Plants per year a	Technical person-hours per year (E=CxD)	Management person-hours per year (F=Ex0.05)	Clerical person-hours per year (G=Ex0.1)	Total Cost per year, $ b
Activity										Labor Rates:
1. Performance Tests: Initial	40	1	40	0	0	0	0	$0		Management	$70.56
2. Performance Tests: Repeat c	40	1	40	0	0	0	0	$0		Technical	$52.37
Reports Review:										Clerical	$28.34
1. Application of construction or reconstruction d	2	1	2	0	0	0	0	$0
2. Notification that source is subject to special compliance requirements d	2	1	2	0	0	0	0	$0
3. Notification of compliance status d	40	1	40	0	0	0	0	$0
4. Notification of storage vessel inspection e	2	6	12	19	228	11.4	22.8	$13,390.90
5. Notification of front-end process vents limit f	2	1	2	0	0	0	0	$0
6. Notification of back-end process vents limit f	2	1	2	0	0	0	0	$0
7. Waiver of recordkeeping or reporting requirements	10	1	10	0	0	0	0	$0
8. Supplemental report for failing to submit information required to be included in reports g	2	1	2	0	0	0	0	$0
9. Implementation plan, precompliance report or permit d	20	1	20	0	0	0	0	$0
10. Updates to emissions averaging plan h	5	1	5	1	5	0.25	0.5	$293.66
11. Semiannual Periodic Reports d, i	4	2	8	16	128	6.4	12.8	$7,517.70
12. Quarterly periodic reports for facilities using emission averaging and where a respondent did not qualify for semiannual reporting d, i	4	4	16	3	48	2.4	4.8	$2,819.14
13. Compliance redetermination report for back-end process operations using a control or recovery device j	10	1	10	2	20	1	2	$1,174.64
14. Report of changes to the primary product for an EPPU or process unit k	2	1	2	2	4	0.2	0.4	$234.93
15. Report of changes or additions to plant sites l	2	1	2	0	0	0	0	$0
16. Malfunction report m	2	2	4	2	8	0.4	0.8	$469.86
TOTAL ANNUAL BURDEN AND COST (rounded) n					507			$25,900
Assumptions:
a We assume there are 19 existing sources subject to the standard and no additional sources per year will be become subject to the standard during 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 the benefit packages available to government: Managerial rate of $70.56 (GS-13, Step 5, $44.10 + 60%), Technical rate of $52.37 (GS-12, Step 1, $32.73 + 60%), and Clerical rate of $28.34 (GS-6, Step 3, $17.17 + 60%). These rates are from the Office of Personnel Management (OPM) “2022 General Schedule” which excludes locality rates of pay.
c This ICR assumes 20% of sources will have to repeat performance tests.
d The burden for these activities are based on similar requirements in the HON NESHAP (Subparts F, G, H, and I).
e This ICR assumes that each facility will refill storage vessels that have been emptied and degassed 6 times per year.
f This ICR assumes that notifications for front- and back-end limits are submitted during the initial compliance period.
g This ICR assumes no respondents will be required to submit supplemental reports.
h This ICR assumes 1 facility per year using an emissions averaging plan will make changes requiring an update to the emissions averaging plan. This activity may also include review of front-end or back-end operations limits.
i This ICR assumes that 5% of sources will not qualify for semiannual reports and will be required to submit quarterly reports. In addition, the 10% of facilities using emissions averaging are required to submit quarterly reports. The remaining sources will all submit semiannual reports.
j This ICR assumes 10% of sources will make a process change that will require a redetermination of compliance report.
k This ICR assumes that 10% of sources will have changes to their primary product.
l This ICR assumes that no respondents will make changes or additions to the plant sites.
m This ICR assumes that 10% of sources will have to submit malfunction reports.
n Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 4: Capital 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)
Monitoring equipment for process vents and wastewater1	$25,000	0	$0	$275,000	19	$5,225,000
Monitoring equipment for equipment leaks1	$7,000	0	$0	$0	0	$0
Totals (rounded) 2			$0			$5,230,000		$5,230,000
1 Capital and O&M costs for process vents, wastewater, and equipment leaks are based on estimates for similar requirements in the HON (Subparts F, G, H and I). The HON uses the following assumptions:
1. Subpart G
-Total Capital/Startup Cost of Monitoring Equipment: The cost to purchase monitoring equipment is approximately $20-30K for process vents and wastewater operations, or an average of $25K with a 10-year life expectancy and a 7 percent depreciation rate, or $2,225 per year. There are no associated costs for transfer racks and storage tanks. Only new sources need to buy monitoring equipment.
-Total Cost of Operation and Maintenance of Monitoring Equipment: The cost to industry associated with O&M is approximately $100-500K per year (capital/startup depreciation not included) for reactor process vents and wastewater operations. The cost associated with the operation and maintenance is $50-100K per year (capital/startup depreciation not included) for distillation unit process vents. There are no associated costs for transfer racks and storage tanks. The average O&M cost is assumed to be the average of the two ranges, or $275,000 per year. Operation and maintenance incur for both new and existing sources.
2. Subpart H
-Total Capital/Startup Cost of Monitoring Equipment: Only new sources will buy an organic volatile analyzer. Estimate the average cost of a monitor is $7,000 with a 5-year expected life. The equipment is not capitalized, so no discount rate applies. The average annual cost is, therefore, $7,000/5, or $1,400/yr.
-Total Cost of Operation and Maintenance of Monitoring Equipment: The operation of the monitors is included in the monitoring equipment costs. Maintenance costs on these units is incidental; therefore, no maintenance or operation costs are incurred.
3. The HON does not estimate any capital or O&M costs for Subparts F and I.
2 Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 5: Responses

Total Annual Responses
(A)	(B)	(C)	(D)	(E)
Information Collection Activity	Number of Respondents	Number of Responses	Number of Existing Respondents That Keep Records But Do Not Submit Reports	Total Annual Responses E=(BxC)+D
Application of construction/reconstruction	0	1	0	0
Request for extension of compliance	0	1	0	0
Notification that source is subject to special compliance requirements	0	1	0	0
Notification of compliance status	0	1	0	0
Notification of storage vessel inspection	19	6	0	114
Notification of front-end process vents limit	0	1	0	0
Notification of back-end process vents limit	0	1	0	0
Progress reports	0	2	0	0
Waiver of recordkeeping or reporting requirements	0	1	0	0
Supplemental report for failing to submit information required to be included in reports	0	1	0	0
Operating permit application	0	1	0	0
Pre-compliance report	0	1	0	0
Emissions averaging plan	0	1	0	0
Updates to emissions averaging plan	1	1	0	1
Request for approval for a nominal control efficiency for use in calculating credits for emission averaging	0	1	0	0
Semiannual periodic reports	16	2	0	32
Quarterly periodic reports	3	4	0	12
Compliance redetermination report	2	1	0	2
Report of changes to the primary product for an EPPU or process unit	2	1	0	2
Report of changes or additions to plant sites	0	1	0	0
Malfunction report	2	2	0	4
			Total	167

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Sheet 6: Respondents

Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
	(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	0	19	0	0	19
2	0	19	0	0	19
3	0	19	0	0	19
Average	0	19	0	0	19
1 New respondents include sources with constructed, reconstructed, and modified affected facilities.