Burden Calculation Tables

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Overview

Summary
Industry
Agency
Capital O&M
Responses
Respondents

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Sheet 1: Summary

ICR Summary Information
Hours per Response	12
Number of Respondents	931
Total Estimated Burden Hours	31,300
Total Estimated Costs	$4,420,000
Annualized Capital O&M	$660,000
Total Annual Responses	2,620
Form Number	Not Applicable

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Sheet 2: Industry

Table 1: Annual Respondent Burden and Cost – NESHAP for Halogenated Solvent Cleaners/Halogenated Hazardous Air Pollutants (40 CFR Part 63, Subpart T) (Renewal)
					123.94	157.61	62.52
Burden Item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (AxB)	(D) Respondents per year a	(E) Technical person-hours per year (CxD)	(F) Management person-hours per year (Ex0.05)	(G) Clerical person-hours per year (Ex0.1)	(H) Total cost per year ($) b
1. Applications
a. Batch vapor and in-line cleaning machines	N/A
b. Batch cold cleaning machines	N/A
2. Survey and studies
a. Batch vapor and in-line cleaning machines	N/A
b. Batch cold cleaning machines	N/A
3. Reporting Requirements
a. Batch vapor and in-line cleaning machines
i. Familiarization with the regulatory requirements c	2	1	2	768	1536	76.8	153.6	$212,079.36
ii. Gather existing information	See 3A(iii)
iii. Write Report										82%
Initial notification report	1	1	1	0	0	0	0	$0		768	batch and in-line vapor machines
Initial compliance report	4	1	4	0	0	0	0	$0		163	cold-cleaning machines
Performance test results d	30	1	30	0	0	0	0	$0
Annual compliance report e	1.5	1	1.5	768	1152	57.6	115.2	$159,059.52		660000	Capital/Startup vs. Operation and Maintenance (O&M) Costs
Report with exceedance f, g	1	4	4	76.8	307.2	15.36	30.72	$42,415.87			Total annual responses
Report with no exceedance f, h	0.5	2	1	691	691.2	34.56	69.12	$95,435.71		768	Annual Compliance Report
b. Batch cold cleaning machines										307.2	Quarterly Exceedance Reports
i. Familiarize with regulatory requirements i	0.5	1	0.5	163	81.5	4.075	8.15	$11,253		1382.4	Semiannual exceedance reports
ii. Gather existing information	See 3B(iii)									163	Batch cold cleaning - recordkeeping
iii. Write Report j										2621
Initial notification report	0.25	1	0.25	0	0	0	0	$0
Initial compliance report	0.25	1	0.25	0	0	0	0	$0
Subtotal for Reporting Requirements					4,333.09			$520,243.37
4. Recordkeeping Requirements
a. Batch vapor and in-line cleaning machines
i. Familiarization with the regulatory requirements	See 3A(i)
ii. Plan activities	N/A
iii. Implement activities
Performance test d	50	1	50	0	0	0	0	$0
Control device monitoring k, l	1.64	12	19.68	384	7557.12	377.856	755.712	$1,043,430.45
Solvent consumption log m	1.5	12	18	384	6912	345.6	691.2	$954,357.12
iv. Record Data
Control device monitoring l, n	1.2	12	14.4	384	5529.6	276.48	552.96	$763,485.70
Solvent emission calculation m, o	0.75	12	9	384	3456	172.8	345.6	$477,178.56
v. Time to train personnel p
b. Batch cold cleaning machines	N/A
Subtotal for Recordkeeping Requirements					26,973			3,238,452		11.9465648854962
TOTAL ANNUAL BURDEN AND COST (rounded) q					31,300			$3,760,000			12	hr per resp
Capital and O&M Cost (see Section 6(b)(iii)): q								$660,000
TOTAL COST: q								$4,420,000
Assumptions:
a. We estimate that an average of 931 existing respondents will be subject to the rule over the three-year period of this ICR. Of this total, 768 respondents are subject to batch vapor and in-line cleaning machine requirements while 163 respondents are subject to batch cold cleaning machine requirements. No new respondents are expected.
b. This ICR uses the following labor rates: Managerial $157.61 ($75.05+ 110%); Technical $123.94 ($59.02 + 110%); and Clerical $62.52 ($29.77 + 110%). 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 percent 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. We assume it will take 2 hours to read instructions.
d. We estimate that idling emission or dwell test reports will require 80 technical hours, which are divided between the test report (30 hours) and the test itself (50 hours).
e. We assume that 768 facilities are required to complete the annual compliance report.
f. The burden of one quarterly and one semiannual exceedance report is included in the burden estimate for the annual report.
g. We assume that 10 percent of 768 facilities are in exceedance at least one time per year (quarterly reporting).
h. We assume that 90 percent of 768 facilities are not in exceedance (semiannual reporting).
i. We assume that it will take 0.5 hours to read instructions.
j. We assume that it will take 0.25 hours to write each report.
k. Actual monitoring is conducted weekly, monthly or quarterly for specific control devices. The estimated time is based on the typical control devices expected to be installed.
l. We assume that 50 percent of the facilities will choose the standard equipment and will be required to conduct control device monitoring.
m. We assume that 50 percent of the facilities will choose to do solvent consumption monitoring.
n. We assume that it will take 1.2 hours per facility to record data.
o. We assume that it will take 0.75 hours per facility to record solvent consumption data.
p. We assume that no special training requirements are required.
q. Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: Agency

Table 2: Average Annual EPA Burden and Cost – NESHAP for Halogenated Solvent Cleaners/Halogenated Hazardous Air Pollutants (40 CFR Part 63, Subpart T) (Renewal)
					52.37	70.56	28.34
Burden Item	(A) Technical person-hours per occurrence	(B) No. of occurrences per respondent per year	(C) Technical person-hours per respondent per year (AxB)	(D) Respondents per year	(E) Technical hours per year (CxD)	(F) Management hours per year (Ex0.05)	(G) Clerical hours per year (Ex0.1)	(H) Total cost per year ($) a
Report Activity
1. Batch vapor and in-line cleaning machine
a. Initial notification report	1	1	1	0	0	0	0	$0
b. Initial compliance report	2	1	2	0	0	0	0	$0
c. Performance test results b	8	1	8	0	0	0	0	$0
d. Annual compliance report c	2	1	2	768	1536	76.8	153.6	$90,212.35
Report with exceedance d, e	1	4	4	76.8	307.2	15.36	30.72	$18,042.47
Report with no exceedance d, f	0.5	2	1	691	691.2	34.56	69.12	$40,595.56
2. Batch Cold Cleaning Machines
a. Initial notification/compliance report	0.25	1	0.25	0	0	0	0	$0
TOTAL ANNUAL BURDEN AND COST (rounded) g					2,910			$149,000
Assumptions:
a. This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for benefit packages available to government employees: 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, $17.71 + 60%). These rates are from the Office of Personnel Management (OPM) “2022 General Schedule” which excludes locality rates of pay.
b. We assume that it will take 8 hours to review performance test results.
c. All facilities are expected to submit annual compliance reports summarizing either solvent consumption data or monitoring results for each cleaning machine.
d. The burden of one quarterly and one semiannual exceedance report is included in the burden estimate for the annual report.
e. We assume that 10 percent of 768 facilities are in exceedance at least one time per year.
f. We assume that 90 percent of 768 facilities are not in exceedance.
g. 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 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)
Temperature monitoring device	$2,700	0	$0	$860	768	$660,480
Total (rounded) a			$0			$660,000		$660,000
a Totals have been rounded to 3 significant digits. 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 a	Number of Responses	Number of Existing Respondents That Keep Records But Do Not Submit Reports	Total Annual Responses E=(BxC)+D
Batch vapor and in-line cleaning machines:
Annual compliance report	768	1	0	768
Quarterly exceedance reports	76.8	4	0	307.2
Semiannual exceedance reports	691.2	2	0	1,382.4
Batch cold cleaning machines:
Initial notification report and compliance report	0	2	163	163
			Total	2,620
Note: Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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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 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	0	768	163	0	931
2	0	768	163	0	931
3	0	768	163	0	931
Average	0	768	163	0	931
a New respondents include sources with constructed and reconstructed affected facilities.