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	478
Number of Respondents	50
Total Estimated Burden Hours	47,800
Total Estimated Costs	$6,650,000
Annualized Capital O&M	$908,000
Total Annual Responses	100

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Sheet 2: Table 1

Table 1: Annual Respondent Burden and Cost – NESHAP for Off-Site Waste and Recovery Operations (40 CFR Part 63, Subpart DD) (Renewal).
						123.94	157.61	62.52
	Burden Items	(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 (CxD)	(F) Managerial person hours per year (Ex0.05)	(G) Clerical person hours per year (Ex0.1)	(H) Total costs per year $ b
	1. Applications	N/A
	2. Survey and Studies	N/A
	3. Reporting Requirements
	A. Familiarize with rule requirement c	4	1	4	50	200	10	20	$27,615
	B. Required Activities	See 4C
	C. Create Information	See 4C
	D. Gather Existing Information	See 4C
	E. Write Reports
	Initial Notification Report d	1	1	1	0	0	0	0	$0
	Performance Test Notification Report d	1	1	1	0	0	0	0	$0
	Compliance Status Notification d	2	1	2	0	0	0	0	$0
	Performance Test Reports d	8	1	8	0	0	0	0	$0
	Semiannual Summary Report e	8	2	16	50	800	40	80	$110,458
	Subtotal for Reporting Requirements					1,150			$138,073
	4. Recordkeeping Requirements
	A. Familiarize with rule requirements	See 3A
	B. Planned Activities	N/A
	C. Implementation of Activities
	a. VOHAP concentration determination
	Commercial Facilities f	2	260	520	25	13,000	650	1,300	$1,794,943
	Other Facilities g	2	12	24	25	600	30	60	$82,844
	b. Vapor Pressure Determination
	Commercial Facilities f	1	260	260	25	6,500	325	650	$897,471
	Other Facilities g	1	12	12	25	300	15	30	$41,422
	c. Control Equipment Visual Inspection
	Large Cover	0.25	10	2.5	50	125	6.25	12.5	$17,259
	Small Cover	0.05	1000	50	50	2500	125	250	$345,181
	Closed Vent System	0.5	5	2.5	50	125	6.25	12.5	$17,259
	d. Control Equipment Leak Monitoring
	Cover Vented to Control Device	1	5	5	50	250	12.5	25	$34,518
	Closed Vent System	1	5	5	50	250	12.5	25	$34,518
	e. Control Devices
	Continuous Monitoring System	8	5	40	50	2,000	100	200	$276,145
	f. LDAR Program
	Perform Monitoring/Repair	80	1	80	50	4,000	200	400	$552,290
	g. PRD monitoring
	Perform Monitoring/Repair	16	1	16	50	800	40	80	$110,458
	D. Develop Record System	N/A
	E. Time to Enter Information
	Control Equipment Inspections	1	1	1	50	50	2.5	5	$6,904
	Control Equipment Monitoring	1	1	1	50	50	2.5	5	$6,904
	Control Device CMS	1	52	52	50	2,600	130	260	$358,989
	LDAR Program	4	16	64	50	3,200	160	320	$441,832
	PRD Program	2	16	32	50	1,600	80	160	$220,916
	Off-site Material Determinations	1	52	52	50	2,600	130	260	$358,989
	F. Time to Train Personnel	N/A
	G. Time for Audits	N/A
	Subtotal for Recordkeeping Requirements					46,633			$5,598,840
	TOTAL ANNUAL BURDEN AND COSTS (rounded): h					47,800			$5,740,000		478	hr per resp
	TOTAL CAPITAL AND O&M COST: h								$908,000
	GRAND TOTAL: h								$6,650,000
	Assumptions:
	a We have assumed that there are approximately 50 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three years.
	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 It is assumed that it will take 4 hours to read instructions.
	d It is assumed that there will be no new sources.
	e The burden of one annual summary report was included in the burden estimate for the semiannual report.
	f It is assumed that 50 percent of the facilities, the owner or operator manages, for a fee, off-site materials received from other generators.
	g It is assumed that 50 percent of the owners or operators accept the off-site material at another location and ship it to the facility for storage, treatment, or disposal.
	h 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 Off-Site Waste and Recovery Operations (40 CFR Part 63, Subpart DD) (Renewal).
						52.37	70.56	28.34
	Activity	(A) EPA Hours/ Occurrence	(B) Occurrences/ Plant/ Year	(C) EPA Hours/ Year (AxB)	(D) Plants/ Year a	(E) Technical Hours/ Year (CxD)	(F) Managerial Hours/ Year (Ex0.05)	(G) Clerical Hours/ Year (Ex0.1)	(H) Costs, $ b
	Report Review
	New Plants c, d
	Initial notification (PRD)	2	1	2	0	0	0	0	$0
	Performance test notification	1	1	1	0	0	0	0	$0
	Compliance status notification	4	1	4	0	0	0	0	$0
	Performance test report e	16	1	16	0	0	0	0	$0
	Existing Plants
	Startup/shutdown report	N/A
	Semiannual summary report f	4	2	8	50	400	20	40	$23,493
	TOTAL ANNUAL BURDEN AND COST (rounded) g					460			$23,500
	Assumptions:
	a We have assumed that there are approximately 50 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three years.
	b This ICR uses the following labor rates: 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%). 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 There will be no travel expenses associated with this ICR since we have assumed that no new sources will become subject to this rule over the three year period of this ICR.
	d It is assumed that there will be no new sources over the three year period of this ICR.
	e It is assumed that it will take 16 hours to review each performance test report.
	f It is assumed that each facility will take 4 hours twice a year to submit report.
	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	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)
O&M a	$0	0	$0	$1,878	50	$93,900
LDAR	$41,254	0	$0	$11,876	50	$593,800
PRD Monitoring Equipment b	$27,000	0	$0	$4,000	50	$200,000
Storage Tanks Duct Work c	$76,412	0	$0	$20,797	1	$20,797
Totals (rounded) d			$0			$908,000		$908,000
a The 2014 proposal ICR (1717.10) states "Based on a previous ICR for the Pesticide Active Ingredient source category, which estimated the annual O&M costs to be $1,450 per source in 2011 dollars, inflating this number from 2011 dollars to 2013 dollars gives $1,505 per source." These are the ongoing costs to maintain the monitor and other costs such as photocopying and postage. These costs have been adjusted from 2013 dollars to 2021 dollars.
b Reflects updated costs for PRD monitoring for stationary sources from the January 29, 2018 final rule (83 FR 3986). The annualized costs per facility (assuming a 15-year equipment life and a seven percent interest rate) are estimated to be approximately $4,000. See memorandum from Carey, A., EPA, “Pressure Relief Device Control Options and Impacts for Off-Site Waste and Recovery Operations (OSWRO) June 26, 2017”, Docket Id. No. EPA-HQ-OAR-2012-0360-0133.
c Costs shown are the total costs for the estimated 21 additional tanks captured under the new 2015 threshold from the March 2015 final rule.
d 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
Initial Notification (PRD)	0	1	0	0
Performance Test Notification	0	1	0	0
Compliance Status Notification	0	1	0	0
Performance Test Report	0	1	0	0
Semiannual report	50	2	0	100
			Total	100
a We have assumed that there are approximately 50 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three years.

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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	50	0	0	50
2	0	50	0	0	50
3	0	50	0	0	50
Average	0	50	0	0	50
a New respondents include sources with constructed and reconstructed affected facilities.