Burden Calculations 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	221
Number of Respondents	41
Total Estimated Burden Hours	17,700
Total Estimated Costs	$2,150,000
Annualized Capital O&M	$18,600
Total Annual Responses	80
Form Number	Not Applicable

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Sheet 2: Table 1

Table 1: Annual Respondent Burden and Cost – NSPS for Rubber Tire Manufacturing (40 CFR Part 60, Subpart BBB) (Renewal)
Burden item	(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 (E=CxD)	(F) Management person- hours per year (F=Ex0.05)	(G) Clerical person hours per year (G=Ex0.1)	(H) Total cost per year b
1. Applications	N/A									Labor Rates
2. Surveys and studies	N/A									Management	$157.61
3. Reporting requirements										Technical	$123.94
A. Familiarize with regulatory requirements c	1	1	1	41	41	2.05	4.1	$5,661.03		Clerical	$62.52
B. Required activities d
Initial performance test e	240	5	1,200	0	0	0	0	0
Repeat initial performance test e	240	1	240	0	0	0	0	$0.00
Monitoring of VOC emissions and operations f	1	350	350	41	14,350	717.5	1,435	$1,981,361.18
Monthly performance tests f, k	2	12	24	0	0	0	0	0
C. Create information	See 3B
D. Gather existing information	See 3E
E. Write report
Notification of actual startup e	2	1	2	0	0	0	0	0
Notification of initial performance test e	2	1	2	0	0	0	0	0
Initial performance test results e	2	1	2	0	0	0	0	0
Notification of Method 25A test g	4	1	4	3	12	0.6	1.2	$1,656.89
Notification of construction/reconstruction	2	1	2	0	0	0	0	0
Report of physical operational changes h	4	2	8	4.1	32.8	1.64	3.28	$4,528.83
Report of spray materials/formulation change h, i	4	2	8	4.1	32.8	1.64	3.28	$4,528.83
Semiannual reports j	10	2	20	13.67	273.4	13.67	27.34	$37,749.42
Annual report of formulation data/Method 24 Results k	4	1	4	41	164	8.2	16.4	$22,644.13
Subtotal for Reporting Requirements					17,142			$2,058,130
4. Recordkeeping requirements
A. Familiarize with regulatory requirements	See 3A
B. Plan activities	See 3B
C. Implement activities	See 3B
D. Develop record system	N/A
E. Time to enter and transmit information l
Record of startup, shutdown, and malfunction	0.5	25	12.5	41	512.5	25.63	51.25	$70,762.90
Records of monthly performance test	See 3B
Records of emissions and operations	See 3B
F. Time to train personnel	N/A
G. Time for audits	N/A
Subtotal for Recordkeeping Requirements					589			$70,763		responses	hr/response
TOTAL LABOR BURDEN AND COST (rounded) m					17,700			$2,130,000		80	221.25
TOTAL CAPITAL AND O&M COST (rounded) m								$18,600
GRAND TOTAL (rounded) m								$2,150,000
Assumptions:
a We have assumed that the average number of respondents that will be subject to the rule will be 41 existing sources, one of which mixes only rubber compound. There will be no additional sources over the three-year period of this ICR. In addition, we have not included the reporting requirements burden for affected facilities exemptions under 40 CFR 60.676(d) in the table because their occurrence is very rare in practice.
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 have assumed all existing sources will have to re-familiarize with the regulatory requirements each year.
d We have assumed that the rubber tire manufacturing plants will not construct or reconstruct an affected facility, however, they will conduct operational changes on 10 percent of the affected operations.
e We have assumed that there will be no new sources expected over the three-year period of this ICR.
f Sources are required to monitor and record monthly performance tests, VOC use, the number of days in each compliance period, control device efficiency, formulation data or the results of Method 24 test analysis conducted to verify the VOC content of the spray, monitoring device data and other operational data such as the number of tires processed. We have assumed that sources will operate approximately 350 days per year or 50 weeks. We have further assumed that the burden incurred to record these items is one hour per occurrence.
g We have assumed that three existing sources using control devices will conduct a Method 25 test once a year to determine the VOC concentration in each stack (source using a capture system) both entering and leaving the control device.
h We have assumed that 10 percent of the existing rubber tire manufacturing plants subject to this rule will make a physical/operational change by adding a green tire spray booth or a new line.
i A source is required to do Method 24 test or formulation data analysis if the operational change involves spray materials formulation changes, and results should be reported within 30 days.
j We have assumed that one-third of the sources will submit exceedance reports for each six month period.
k We have assumed that all existing sources, will submit an annual Method 24 test report or an annual formulation data report to verify the VOC content of each tread end cement and green tire spray material in lieu of conducting a monthly performance test. We have further assumed that 50 percent of the existing sources, will continue to use hazardous air pollutant (HAP) materials (VOC) in the spray at levels that meet the green tire VOC limitations in NSPS not needing to add on control devices. The remaining plants will use only water-based sprays and are not required to perform monthly performance tests. We have assumed that the burden incurred to record these items is one hour per occurrence per source due to the nature of the control equipment used and its intermittent use.
l We have assumed that there will be two occurrences of startup, shutdown, and/or malfunction per source every four weeks, which will yield and average of 25 occurrences per source per respondent in 50 weeks.
m 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 - NSPS for Rubber Tire Manufacturing (40 CFR Part 60, Subpart BBB) (Renewal)
Activity	(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 (F=Ex0.05)	(G) Clerical person- hours per year (G=Ex0.1)	(H) Total cost per year b
Notification of actual startup c	2	1	2	0	0	0	0	$0		Labor Rates
Notification of initial performance test c	2	1	2	0	0	0	0	$0		Management	$70.56
Report of performance test results c	2	1	2	0	0	0	0	$0		Technical	$52.37
Notification of construction/reconstruction c	2	1	2	0	0	0	0	$0		Clerical	$28.34
Notification of Method 25A test d	8	1	8	3	24	1.2	2.4	$1,410
Notification of change in spray materials formulation e	2	1	2	4.1	8.2	0.41	0.82	$482
Semiannual reports f	4	2	8	13.67	109.36	5.47	10.94	$6,423
Annual report of formulation data/Method 24 test results g	5	1	5	41	205	10.25	20.5	$12,040
Report of physical/operational changes h	4	1	4	4.1	16.4	0.82	1.64	$963
TOTAL LABOR BURDEN AND COST (rounded) i					417			$21,300
Assumptions:
a We have assumed that the average number of respondents that will be subject to the rule will be 41 existing sources one of which mixes only rubber compound. There will be no additional sources over the three-year period 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, $17.17 + 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 have assumed that there will be no new sources expected over the three-year period of this ICR.
d We have assumed that three existing sources using control devices will conduct a Method 25 test once a year to determine the VOC concentration in each stack (source using a capture system) both enter and leaving the control device.
e We have assumed that a source is required to do Method 24 or formulation data analysis if the operational change involves spray materials formulation changes and results should be reported within 30 days.
f We have assumed that one-third of sources will submit exceedance reports for each six month period.
g We have assumed that all existing sources will submit an annual Method 24 test report or an annual formulation data report to verify the VOC content of each tread end cement and green tire spray material in lieu of conducting a monthly performance test. We have further assumed that 50 percent of the existing sources will continue to use HAP materials (VOC) in the spray at levels that meet the green tire VOC limitations in NSPS not needing any add on control devices. The remaining plants use only water-based sprays and are not required to do monthly performance tests. We have assumed that the burden incurred to record these items is five hours per occurrence per source due to the nature of the control equipment used and its intermittent use.
h We have assumed that ten percent of the existing rubber tire manufacturing plants subject to the rule will make a physical/operational change due to adding a green tire spray booth or a new line.
i 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) b	Annual O&M Costs for One Respondent	Number of Respondents with O&M	Total O&M, (E X F) b
VOC (organics) monitor 1, 3	$39,716	0	$0	$8,511	0	$0
Temperature monitors at thermal and catalytic incinerators 1, 3	$8,511	0	$0	$4,539	4.1	$18,610
Total 2			$0			$18,600
1 We assume no facilities are using an organics monitor or carbon absorber at this time. An estimated 10 percent of respondents use a temperature monitor.
2 Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
3 Capital and O&M costs have been increased from 2007 to 2020 $ using the CEPCI Equipment Cost Index.
					C/S and O&M	$18,600

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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
Notification of Method 25A test	3	1	0	3
Report of physical/operational changes	4.1	1	0	4.1
Notification of change in spray materials formulation	4.1	1	0	4.1
Semiannual report of excess emissions	13.67	2	0	27.34
Annual report of formulation data/Method 24	41	1	0	41
			TOTAL (rounded)	80

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Sheet 6: Respondents

Number of Respondents
	Respondents that submit reports		Respondents that do not submit any reports
Year	(A) Number of New Respondents 1	(B) Number of Existing Respondents	(C) Number of Existing Respondents that keep records but do not submit reports	(D) Number of Existing Respondents that are also new respondents	(E) Number of Respondents (E=A+B+C+D)
1	0	41	0	0	41
2	0	41	0	0	41
3	0	41	0	0	41
Average	0	41	0	0	41
1 New respondents include sources with constructed, reconstructed, and modified affected facilities