Burden Calculation Table

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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	198
Number of Respondents	3
Total Estimated Burden Hours	2,240
Total Estimated Costs	$302,000
Annualized Capital O&M	$33,000
Total Annual Responses	11
Form Number	Not applicable

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Sheet 2: Table 1

Table 1: Annual Respondent Burden and Cost – NESHAP for Magnetic Tape Manufacturing Operations (40 CFR Part 63, Subpart EE) (Renewal)
Burden Items	(A) Hours per Occurrence	(B) Occurrences per Year	(C) Hours per Year (C=AxB)	(D) Respondents per Year a	(E) Technical Person Hours per Year (E=CxD)	(F) Managerial Hours per Year (F=Ex0.05)	(G) Clerical Hours per Year (G=Ex0.10)	(H) Total Cost per Year ($) b
1. Applications	N/A									Labor Rates
2. Survey and Studies	N/A									Management	$157.61
3. Reporting Requirements										Technical	$123.94
A. Familiarize with Regulatory Requirements c	1	1	1	3	3	0.2	0.3	$414.22		Clerical	$62.52
B. Required Activities
Tests
Initial performance test - APCD d	445	1	445	0	0	0	0	$0
Conduct performance test method audits d	27	1	27	0	0	0	0	$0
Repeat initial performance test - APCD e	445	1	445	0	0	0	0	$0
Repeat performance test method audits e	27	1	27	0	0	0	0	$0
Initial performance pest - total enclosure d, g	215	1	215	1	215	10.75	21.5	$29,685.90
Repeat initial performance test - total enclosure e	215	1	215	0.6	129	6.45	12.9	$17,811.54
Performance test for VOC CEMs d	175	1	175	0	0	0	0	$0.00
Quarterly VOC CEM audits f	10	4	40	2	80	4	8	$11,045.92
C. Create Information	See 3B & 4E
D. Gather Existing Information	See 3B & 4E
E. Write Reports
Notification of intent to construct/reconstruct g	6	1	6	1	6	0.3	0.6	$828.44
Notification of construction date g	2	1	2	1	2	0.1	0.2	$276.15
Actual startup notification g	2	1	2	1	2	0.1	0.2	$276.15
Notification of applicability of the standard existing sources h	2	1	2	0	0	0	0	$0.00
Notification of applicability of the standard new/reconstructed sources g	2	1	2	1	2	0.1	0.2	$276.15
Notification of initial performance test i	2	1	2	1	2	0.1	0.2	$276.15
Report of initial test	See 3B
Notification of compliance status j	4	1	4	0	0	0	0	$0
Submit startup, shutdown, malfunction plan j	20	1	20	0	0	0	0	$0
Develop and implement quality control plan for continuous monitoring systems (CMS) j	50	1	50	0	0	0	0	$0
Report when exceed HAP usage cutoff (or report area source becoming major sources) k	2	1	2	0	0	0	0	$0
Waiver application h	6	1	6	0	0	0	0	$0
Report of monitoring exceedances and periods of noncompliance, including inconsistencies with startup, shutdown, and malfunction reports l	16	4	64	0.3	19.2	0.96	1.92	$2,651
Report of no excess emissions, including startup, shutdown, malfunction reports l	4	2	8	2.7	21.6	1.08	2.16	$2,982
Subtotal for Reporting Requirements					554			$66,524
4. Recordkeeping Requirements
A. Familiarize with Regulatory Requirements c	See 3A
B. Plan Activities	N/A
C. Implement Activities	See 4D
D. Develop Record System j, m	40	1	40	0	0	0	0	$0
E. Time to enter information
Facilities above cutoff, including records associated with startup, shutdown, malfunction, maintenance of APCD, and measurement of freeboard ratio n	0.5	350	175	3	525	26.25	52.5	$72,488.82
Maintain, adjust, and calibrate CMS and maintain records of this and any CMS malfunction that occurs o	6	52	312	3	936	46.8	93.6	$129,237.22
Facilities below cutoff p	2	1	2	1	2	0.1	0.2	$276.15
F. Time to Train Personnel	N/A
G. Time for Audits	N/A
Subtotal for Recordkeeping Requirements					1,682			$202,002	Responses	11
Total Labor Burden and Cost (rounded) q					2,240			$269,000	hours/response	198
Total Capital and O&M Cost (rounded) q								$33,000
Grand Total (rounded) q								$302,000
Assumptions:
a We have assumed there are approximately 3 sources currently subject to the standard and no additional sources will become subject to the standard over the three years of this ICR.
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 the benefit packages available to those employed by private industry.
c We assume that all respondents will have to familiarize themselves with regulatory requirements each year.
d Hours associated with the initial performance test include preparation of site-specific test plan. Hours for performance test method audits are estimated as 6 percent of the performance test hours. No facility is expected to conduct testing for the air pollution control device (APCD) and CEMS.
e We have assumed 20 percent of sources will have to repeat initial performance tests.
f All facilities using VOC continuous emission monitors (CEMs) will have to perform quarterly audits of monitors, estimated at two facilities.
g It is projected that, on average, new coating lines will be added at the rate of one per year. These coating lines will be located at existing facilities which will already be meeting the reporting and recordkeeping requirements of the standard. Also, additional emission points are likely to be tied into the existing APCD. Therefore, new compliance tests for the APCD and continuous monitors will not be necessary. However, a new total enclosure would be built and must be tested.
h This is a one time activity.
i One new total enclosure will be tested per year.
j No facilities are expected to be required to report on status, or develop a startup, shutdown, malfunction plan, quality control plan for continuous monitoring system (CMS), or record system.
k No existing area sources are expected to exceed the HAP usage cutoff or become a major source.
l These reports will include data based on CMS performance and/or material balance results. It is assumed to 90 percent of the facilities in this source category will have no excess emission: reporting will therefore be semiannual. We assume that 10 percent of the facilities in this source category will be submitting reports.
m Activities that must be implemented at all facilities include maintaining a 75 percent freeboard ration in wash sinks, the use of a closed system for flushing fixed lines, and the use of a closed system for particulate transfer. A record system will need to be developed to maintain records associated with the freeboard ratio, performance test, notification, and CMS QA/QC program.
n All facilities subject to the control requirements of the standard will be keeping records.
o All but one of the 3 facilities subject to the rule will operate a CMS, as defined in Section 63.2 of the General Provisions. The one facility that will not operate a CMS has only one control device and will be keeping records.
p Facilities that fall below the HAP usage cutoff will have to submit an annual report certifying this usage. We assume one facility is subject to this requirement.
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 Magnetic Tape Manufacturing Operations (40 CFR Part 63, Subpart EE) (Renewal)
Activity	(A) EPA Hours per Occurrence	(B) Occurrences per Year	(C) EPA Hours per Year (C=AxB)	(D) Plants per Year a	(E) Technical Hours per Year (E=CxD)	(F) Managerial Hours per Year (F=Ex0.05)	(G) Clerical Hours per Year (G=Ex0.10)	(H) Cost, $ b
										Labor Rates
Initial performance test - APCD c	60	0	0	0	0	0	0	$0		Management	$70.56
Repeat initial performance test d										Technical	$52.37
1. Retesting preparation	16	0	0	0	0	0	0	$0		Clerical	$28.34
2. Retesting	60	0	0	0	0	0	0	$0
Report Review					0	0	0	$0
Notification of construction/reconstruction e, f	2	1	2	1	2	0.1	0.2	$117
Notification of construction date f	2	1	2	1	2	0.1	0.2	$117
Notification of actual startup f	2	1	2	1	2	0.1	0.2	$117
Notification of applicability -existing sources e	2	0	0	0	0	0	0	$0
Notification of applicability - new/ reconstruction sources f	2	1	2	1	2	0.1	0.2	$117
Notification of initial performance test - total enclosure g	2	1	2	1	2	0.1	0.2	$117
Report of initial performance test g	8	1	8	1	8	0.4	0.8	$470
Notification of compliance status e	4	0	0	0	0	0	0	$0
Startup, shutdown, malfunction plan h	4	0	0	0	0	0	0	$0
Quality control plan for CMS h	4	0	0	0	0	0	0	$0
Report of monitoring exceedances and periods of noncompliance l	8	4	32	0.3	9.6	0.48	0.96	$564
Report of no excess emissions l	2	2	4	2.7	10.8	0.54	1.08	$634
Report for facilities below cutoff i	1	1	1	1	1	0.05	0.1	$59
Report of area source becoming a major source or exceeding HAP usage cutoff j	8	0	0	0	0	0	0	$0
Waiver application k	8	0	0	0	0	0	0	$0
Total Cost (rounded) m					45			$2,310
Assumptions:
a We have assumed there are approximately 3 sources currently subject to the standard and no additional sources will become subject to the standard over the three years of this ICR.
b This cost is based on the average hourly labor rate as follows: Managerial $70.56 (GS-13, Step 5, $44.10 + 60%); Technical $52.37 (GS-12, Step 1, $32.73 + 60%); and Clerical $28.34 (GS-6, Step 3, $17.71 + 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), 2022 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 assume that 10 percent of the tests conducted are attended by EPA.
d We assume that 20 percent will fail the initial performance tests and will have to be retested.
e This is a one time activity.
f We assume that one new coating line will be added per year. This line will be at an existing facility.
g This is based on one facility conducting tests, including retesting. It is projected that, on average, new coating lines will be added at the rate of one per year. These coating lines will be located at existing facilities which will already be meeting the reporting and recordkeeping requirements of the standard. Also, additional emission points are likely to be tied into the existing APCD. Therefore, new compliance tests for the APCD and continuous monitors will not be necessary. However, a new total enclosure would be built and must be tested.
h We assume that EPA will not review startup, shutdown, malfunction plans and CMS quality control plans.
i There will be one existing facility expected to be below the solvent usage cutoff.
j We assume that no existing area sources are expected to exceed the HAP usage cutoff or become area sources.
k We assume that all waiver applications have been submitted.
l It is assumed to 90 percent of the facilities in this source category will have no excess emission: reporting will therefore be semiannual. We assume that 10 percent of the facilities in this source category will be submitting reports.
m 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)
Total enclosure	$11,000	1	$11,000	0	0	0
VOC CEM	$0	0	$0	$8,000	2	$16,000
Thermo-couples	$0	0	$0	$2,000	3	$6,000
Totals			$11,000			$22,000
Totals (rounded) 2			$11,000			$22,000		$33,000
1 This ICR assumes three sources are currently subject to the NESHAP, and that no additional source will become subject in the next three years. However, we estimate that one of the three of the existing sources will incur capital costs due to modification or reconstruction.
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 a	Number of Responses	Number of Existing Respondents That Keep Records But Do Not Submit Reports	Total Annual Responses E=(BxC)+D
Report of monitoring exceedances and periods of non-compliance	0.3	3	0	0.9
Report of no excess emissions	2.7	2	0	5.4
Notification of Intent to Construct/Reconstruct1	1	1	0	1
Notification of Construction Date	1	1	0	1
Actual Startup Notification	1	1	0	1
Notification of Applicability of the Standard New/Reconstructed Sources	1	1	0	1
Notification of initial performance test – total enclosure2	1	1	0	1
			Total	11
1Respondents are new coating lines at existing facilities.
2 New compliance tests for the APCD and continuous monitors will not be necessary. However, a new total enclosure would be built and must be tested for each new line anticipated.

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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	1	3	0	1	3
2	1	3	0	1	3
3	1	3	0	1	3
Average	1	3	0	1	3
1 New respondents include sources with constructed, reconstructed and modified affected facilities. In this standard existing respondents submit initial notifications. On average, new coating lines will be added at the rate of one per year. These coating lines will be located at existing facilities which will already be meeting the reporting and recordkeeping requirements of the standard.