Burden Calculation Sheets

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Overview

Cover
Table 1
Table 2
Table 3
Table 4
Table 5
Table 6
Table 7
Table 8
Additional Tables

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Sheet 1: Cover

ATTACHMENT 1

SUPPORTING STATEMENT

Review of the NESHAP for Epoxy Resin and Non-Nylon Polyamide Production (40 CFR Part 63, Subpart W) (Proposed Rule)

TABLES 1, 2, and 3

Annual Respondent Burden and Cost of the Review of the NESHAP for Epoxy Resin and Non-Nylon Polyamide Production (40 CFR Part 63, Subpart W) (Proposed Rule) - Years 1-3

TABLE 4

Summary of Annual Respondent Burden and Cost of the Review of the NESHAP for Epoxy Resin and Non-Nylon Polyamide Production (40 CFR Part 63, Subpart W) (Proposed Rule)

TABLES 5, 6, and 7

Annual Agency Burden and Cost of the Review of the Review of the NESHAP for Epoxy Resin and Non-Nylon Polyamide Production (40 CFR Part 63, Subpart W) (Proposed Rule) - Years 1-3

TABLE 8

Summary of Annual Agency Burden and Cost of the Review of the Review of the NESHAP for Epoxy Resin and Non-Nylon Polyamide Production (40 CFR Part 63, Subpart W) (Proposed Rule)

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Sheet 2: Table 1

Table 1: Annual Respondent Burden and Cost Year 1 – Review of the NESHAP for Epoxy Resin and Non-Nylon Polyamide Production (40 CFR Part 63, Subpart W) (Proposed Rule)
Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (A x B)	(D) Respondents per year a	(E) Technical person- hours per year (C x D)	(F) Management person hours per year (E x0.05)	(G) Clerical person hours per year (E x 0.1)	(H) Total Cost per year b
1. Applications	N/A									Labor Rates
2. Surveys and studies	N/A									Management	$161.34
3. Reporting requirements										Technical	$101.24
A. Familiarization with the regulatory requirements a	8	1	8	5	40	2.0	4	$4,553		Clerical	$45.17
B. Required activities c
Basic liquid resins (BLR)	1,050	1	1,050	0	0	0	0	$0
Repeat initial performance test - process vents	1,050	1	1,050	0	0	0	0	$0
Initial performance test - wastewater	270	1	270	0	0	0	0	$0
Repeat initial performance test – wastewater	270	1	270	0	0	0	0	$0
Wet strength resins (WSR) d	270	1	270	0	0	0	0	$0
C. Create information	See 3B, 4D, 4E
D. Gather existing information	See 3B, 4D, 4E
E. Write report
Notification of construction/reconstruction c	2	1	2	0	0	0	0	$0
Notification of physical/operational changes e	2	1	2	0	0	0	0	$0
Notification of anticipated startup c	2	1	2	0	0	0	0	$0
Notification of actual startup c	2	1	2	0	0	0	0	$0
Notification of applicability of the standard – existing sources c	2	1	2	0	0	0	0	$0
Notification of applicability of the standard – new sources c	2	1	2	0	0	0	0	$0
Notification of initial performance test c	2	1	2	0	0	0	0	$0
Report of initial test (including CMS performance evaluation and results) c	6	1	6	0	0	0	0	$0
Submit quality control plan for CMS c, f	2	1	2	0	0	0	0	$0
Submit startup, shutdown, malfunction plan c	2	1	2	0	0	0	0	$0
Report of monitoring exceedances and periods of noncompliance g	16	4	64	0	0	0	0	$0
Report of no excess emissions h	8	4	32	0	0	0	0	$0
Report of area source becoming major i	6	1	6	0	0	0	0	$0
Waiver application j	6	1	6	0	0	0	0	$0
Compliance status information report c	4	1	4	0	0	0	0	$0
Submit semiannual SSM reports k	2	2	4	0	0	0	0	$0
Submit immediate reports of inconsistent procedures monitored at each affected source h	2	1	2	0	0	0	0	$0
Submit a CMS summary report for HAP monitored at each affected source l	2	1	2	0	0	0	0	$0
Subtotal for Reporting Requirements					46			$4,553
4. Recordkeeping requirements
A. Familiarization with the regulatory requirements a	See 3A
B. Plan activities	N/A
C. Implement activities	See 4D, 4E
D. Develop record system c	40	1	40	0	0	0	0	$0
E. Time to enter information
a. Records of control device monitoring parameters:
- Continuously monitored parameters l, m	12	52	624	0	0	0	0	$0
- LDAR program reporting and recordkeeping – BLR l	311	1	311	0	0	0	0	$0
- LDAR program reporting and recordkeeping – WSR n	11	1	11	0	0	0	0	$0
- Wastewater parameters l, o	2	12	24	0	0	0	0	$0
- Records of operating parameters to meet D/F emission limit	1	52	52	0	0	0	0	$0
b. Record Information:
- Maintenance Vents	1	1	1	0	0	0	0	$0
- Pressure Relief Device - Releases to Atmosphere r	1	1	1	0	0	0	0	$0
- Heat Exchange System Recordkeeping	1	1	1	0	0	0	0	$0
F. Other recordkeeping activities
a. Maintain records of occurrence and duration of each SSM of process and control equipment h, p	2	8	16	0	0	0	0	$0
b. Maintain records of maintenance performed on air pollution control equipment h	2	4	8	0	0	0	0	$0
c. Maintain records of all action taken during periods of SSM that differ from the sources SSM plan h, q	2	1	2	0	0	0	0	$0
d. Maintain records of each period during which a CMS is malfunctioning or inoperative l	2	1	2	0	0	0	0	$0
e. Maintain records of result of all performance test and performance evaluations c	2	1	2	0	0	0	0	$0
f. Maintain all initial notification and compliance status notifications c	1	1	1	0	0	0	0	$0
G. Time for audits	N/A
H. Time to train personnel	8	1	8	0	0	0	0	$0
Subtotal for Recordkeeping Requirements					0			$0
Total Labor Burden and Costs (rounded) s					46			$4,550
Total Capital and O&M Cost (rounded) s								$0
Grand Total (rounded) s								$4,550
Assumptions:
a We have assumed that the average number of existing sources subject to the rule will be five. There will be no additional new sources per year that will become subject to the rule over the three-year period of this ICR. We assume that each respondent will have to familiarize with the regulatory requirements each year. We have assumed that one-third of the facilities would begin complying in year 2 and the remaining facilities in year 3. It is anticipated facilities will read the rule in year 1.
b This ICR uses the following labor rates for privately-owned sources: $161.34 for managerial, $101.24 for technical, and $45.17 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, May 2021, National Industry-Specific Occupational Employment and Wage Estimates for NAICS 325000 - Chemical Manufacturing. These rates have been adjusted using a Fringe Benefit Loading Rate of 1.5 and an Overhead and Profit Rate of 1.4 (Mean Hourly Rate * Fringe Benefit Loading Rate * Overhead and Profit Rate = Loaded Rate) 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 that this is a one-time-only cost. Records for one-time reporting activities must only be retained for five years. The five year period after these initial activities precedes the period covered by this ICR renewal.
d For all wet strength resins (WSR) facilities, as an alternative to implementing the standards for process vents, storage tanks, and wastewater, these facilities may elect to comply with the requirements of 40 CFR part 63, subpart H - leak detection and repair program for equipment leaks. Because it is more cost effective, we have assumed that all WSR facilities will choose to comply with the alternative standard. These facilities are not required to have the continuous monitoring systems (CMS) installed. Note that this item is not included in the incremental burden presented in this ICR.
e We have assumed that no facilities will have a physical or operational change.
f We have assumed that it will require one test each for wastewater and process vents. Note that this item is not included in the incremental burden presented in this ICR.
g We have assumed that one facility will have excess emissions. Note that this item is not included in the incremental burden presented in this ICR.
h We have assumed that there are five sources that are subject to this regulation, so the number of sources without excess emissions report is four. Note that this item is not included in the incremental burden presented in this ICR.
i We have assumed that no area sources are expected to become major sources.
j We have assumed that one facility will require a waiver. Note that this item is not included in the incremental burden presented in this ICR.
k We have assumed that it will take each respondent two hours to submit semiannual (SSM) reports. Also quarterly reporting may be reduced to semiannual reporting for sources that are in compliance for one year. The proposed amendments will remove the SSM exemption and the requirement to submit SSM reports will no longer apply three years after publication of the final rule. We have not included additional burden for SSM requirements in the incremental burden presented in this ICR.
l We have assumed that there are three basic liquid resins (BLR) manufacturing facilities. Note that this item is not included in the incremental burden presented in this ICR.
m We have assumed that these parameters will automatically be recorded with a data logger.
n We have assumed that there are four WSR facilities subject to the rule. Note that this item is not included in the incremental burden presented in this ICR.
o We have assumed that it will take two hours to record wastewater parameters during the monthly monitoring.
p We have assumed that startup, shutdown, and/or malfunction (SSM) will occur eight times per year for each facility. The proposed amendments will remove the SSM exemption and the SSM recordkeeping requirements will no longer apply three years after publication of the final rule. We have not included additional burden for SSM requirements in the incremental burden presented in this ICR.
q We have assumed that it will take two hours once per year for each facility to maintain records for one deviation from SSM plans. The proposed amendments will remove the SSM exemption and the SSM recordkeeping requirements will no longer apply three years after publication of the final rule. We have not included additional burden for SSM requirements in the incremental burden presented in this ICR.
r We have assumed that no respondents will have a relief valve discharge to the atmosphere during the three-year period of this ICR.
s 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: Annual Respondent Burden and Cost Year 2 – Review of the NESHAP for Epoxy Resin and Non-Nylon Polyamide Production (40 CFR Part 63, Subpart W) (Proposed Rule)
Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (A x B)	(D) Respondents per year a	(E) Technical person- hours per year (C x D)	(F) Management person hours per year (E x0.05)	(G) Clerical person hours per year (E x 0.1)	(H) Total Cost per year b
1. Applications	N/A									Labor Rates
2. Surveys and studies	N/A									Management	$161.34
3. Reporting requirements										Technical	$101.24
A. Familiarization with the regulatory requirements a	1	1	1	5	5	0.3	0.5	$569		Clerical	$45.17
B. Required activities c
Basic liquid resins (BLR)	1,050	1	1,050	0	0	0	0	$0
Repeat initial performance test - process vents	1,050	1	1,050	0	0	0	0	$0
Initial performance test - wastewater	270	1	270	0	0	0	0	$0
Repeat initial performance test – wastewater	270	1	270	0	0	0	0	$0
Wet strength resins (WSR) d	270	1	270	0	0	0	0	$0
C. Create information	See 3B, 4D, 4E
D. Gather existing information	See 3B, 4D, 4E
E. Write report
Notification of construction/reconstruction c	2	1	2	0	0	0	0	$0
Notification of physical/operational changes e	2	1	2	0	0	0	0	$0
Notification of anticipated startup c	2	1	2	0	0	0	0	$0
Notification of actual startup c	2	1	2	0	0	0	0	$0
Notification of applicability of the standard – existing sources c	2	1	2	0	0	0	0	$0
Notification of applicability of the standard – new sources c	2	1	2	0	0	0	0	$0
Notification of initial performance test c	2	1	2	2	4	0.2	0.4	$455
Report of initial test (including CMS performance evaluation and results) c	6	1	6	2	12	0.6	1.2	$1,366
Submit quality control plan for CMS c, f	2	1	2	0	0	0	0	$0
Submit startup, shutdown, malfunction plan c	2	1	2	0	0	0	0	$0
Report of monitoring exceedances and periods of noncompliance g	16	4	64	0	0	0	0	$0.00
Report of no excess emissions h	8	4	32	0	0	0	0	$0.00
Report of area source becoming major i	6	1	6	0	0	0	0	$0
Waiver application j	6	1	6	0	0	0	0	$0.00
Compliance status information report c	4	1	4	2	8	0.4	0.8	$911
Submit semiannual SSM reports k	2	2	4	0	0	0	0	$0.00
Submit immediate reports of inconsistent procedures monitored at each affected source h	2	1	2	0	0	0	0	$0.00
Submit a CMS summary report for HAP monitored at each affected source l	2	1	2	0	0	0	0	$0.00
Subtotal for Reporting Requirements					33			$3,301
4. Recordkeeping requirements
A. Familiarization with the regulatory requirements a	See 3A
B. Plan activities	N/A
C. Implement activities	See 4D, 4E
D. Develop record system c	40	1	40	0	0	0	0	$0
E. Time to enter information
a. Records of control device monitoring parameters:
- Continuously monitored parameters l, m	12	52	624	0	0	0	0	$0.00
- LDAR program reporting and recordkeeping – BLR l	311	1	311	0	0	0	0	$0.00
- LDAR program reporting and recordkeeping – WSR n	11	1	11	0	0	0	0	$0.00
- Wastewater parameters l, o	2	12	24	0	0	0	0	$0.00
- Records of operating parameters to meet D/F emission limit	1	52	52	2	104	5.2	10.4	$11,837.70
b. Record Information:
- Maintenance Vents	1	1	1	2	2	0.1	0.2	$227.65
- Pressure Relief Device - Releases to Atmosphere r	1	1	1	0	0	0	0	$0.00
- Heat Exchange System Recordkeeping	1	1	1	2	2	0.1	0.2	$227.65
F. Other recordkeeping activities
a. Maintain records of occurrence and duration of each SSM of process and control equipment h, p	2	8	16	0	0	0	0	$0.00
b. Maintain records of maintenance performed on air pollution control equipment h	2	4	8	0	0	0	0	$0.00
c. Maintain records of all action taken during periods of SSM that differ from the sources SSM plan h, q	2	1	2	0	0	0	0	$0.00
d. Maintain records of each period during which a CMS is malfunctioning or inoperative l	2	1	2	0	0	0	0	$0.00
e. Maintain records of result of all performance test and performance evaluations c	2	1	2	0	0	0	0	$0
f. Maintain all initial notification and compliance status notifications c	1	1	1	0	0	0	0	$0
G. Time for audits	N/A
H. Time to train personnel	8	1	8	2	16	0.8	1.6	$1,821
Subtotal for Recordkeeping Requirements					143			$14,114
Total Labor Burden and Costs (rounded) s					176			$17,400
Total Capital and O&M Cost (rounded) s								$1,850,000
Grand Total (rounded) s								$1,870,000
Assumptions:
a We have assumed that the average number of existing sources subject to the rule will be five. There will be no additional new sources per year that will become subject to the rule over the three-year period of this ICR. We assume that each respondent will have to familiarize with the regulatory requirements each year. We have assumed that one-third of the facilities would begin complying in year 2 and the remaining facilities in year 3. It is anticipated facilities will read the rule in year 1.
b This ICR uses the following labor rates for privately-owned sources: $161.34 for managerial, $101.24 for technical, and $45.17 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, May 2021, National Industry-Specific Occupational Employment and Wage Estimates for NAICS 325000 - Chemical Manufacturing. These rates have been adjusted using a Fringe Benefit Loading Rate of 1.5 and an Overhead and Profit Rate of 1.4 (Mean Hourly Rate * Fringe Benefit Loading Rate * Overhead and Profit Rate = Loaded Rate) 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 that this is a one-time-only cost. Records for one-time reporting activities must only be retained for five years. The five year period after these initial activities precedes the period covered by this ICR renewal.
d For all wet strength resins (WSR) facilities, as an alternative to implementing the standards for process vents, storage tanks, and wastewater, these facilities may elect to comply with the requirements of 40 CFR part 63, subpart H - leak detection and repair program for equipment leaks. Because it is more cost effective, we have assumed that all WSR facilities will choose to comply with the alternative standard. These facilities are not required to have the continuous monitoring systems (CMS) installed. Note that this item is not included in the incremental burden presented in this ICR.
e We have assumed that no facilities will have a physical or operational change.
f We have assumed that it will require one test each for wastewater and process vents. Note that this item is not included in the incremental burden presented in this ICR.
g We have assumed that one facility will have excess emissions. Note that this item is not included in the incremental burden presented in this ICR.
h We have assumed that there are five sources that are subject to this regulation, so the number of sources without excess emissions report is four. Note that this item is not included in the incremental burden presented in this ICR.
i We have assumed that no area sources are expected to become major sources.
j We have assumed that one facility will require a waiver. Note that this item is not included in the incremental burden presented in this ICR.
k We have assumed that it will take each respondent two hours to submit semiannual (SSM) reports. Also quarterly reporting may be reduced to semiannual reporting for sources that are in compliance for one year. The proposed amendments will remove the SSM exemption and the requirement to submit SSM reports will no longer apply three years after publication of the final rule. We have not included additional burden for SSM requirements in the incremental burden presented in this ICR.
l We have assumed that there are three basic liquid resins (BLR) manufacturing facilities. Note that this item is not included in the incremental burden presented in this ICR.
m We have assumed that these parameters will automatically be recorded with a data logger.
n We have assumed that there are four WSR facilities subject to the rule. Note that this item is not included in the incremental burden presented in this ICR.
o We have assumed that it will take two hours to record wastewater parameters during the monthly monitoring.
p We have assumed that startup, shutdown, and/or malfunction (SSM) will occur eight times per year for each facility. The proposed amendments will remove the SSM exemption and the SSM recordkeeping requirements will no longer apply three years after publication of the final rule. We have not included additional burden for SSM requirements in the incremental burden presented in this ICR.
q We have assumed that it will take two hours once per year for each facility to maintain records for one deviation from SSM plans. The proposed amendments will remove the SSM exemption and the SSM recordkeeping requirements will no longer apply three years after publication of the final rule. We have not included additional burden for SSM requirements in the incremental burden presented in this ICR.
r We have assumed that no respondents will have a relief valve discharge to the atmosphere during the three-year period of this ICR.
s Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 4: Table 3

Table 3: Annual Respondent Burden and Cost Year 3 – Review of the NESHAP for Epoxy Resin and Non-Nylon Polyamide Production (40 CFR Part 63, Subpart W) (Proposed Rule)
Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (A x B)	(D) Respondents per year a	(E) Technical person- hours per year (C x D)	(F) Management person hours per year (E x0.05)	(G) Clerical person hours per year (E x 0.1)	(H) Total Cost per year b
1. Applications	N/A									Labor Rates
2. Surveys and studies	N/A									Management	$161.34
3. Reporting requirements										Technical	$101.24
A. Familiarization with the regulatory requirements a	1	1	1	5	5	0.3	0.5	$569		Clerical	$45.17
B. Required activities c
Basic liquid resins (BLR)	1,050	1	1,050	0	0	0	0	$0
Repeat initial performance test - process vents	1,050	1	1,050	0	0	0	0	$0
Initial performance test - wastewater	270	1	270	0	0	0	0	$0
Repeat initial performance test – wastewater	270	1	270	0	0	0	0	$0
Wet strength resins (WSR) d	270	1	270	0	0	0	0	$0
C. Create information	See 3B, 4D, 4E
D. Gather existing information	See 3B, 4D, 4E
E. Write report
Notification of construction/reconstruction c	2	1	2	0	0	0	0	$0
Notification of physical/operational changes e	2	1	2	0	0	0	0	$0
Notification of anticipated startup c	2	1	2	0	0	0	0	$0
Notification of actual startup c	2	1	2	0	0	0	0	$0
Notification of applicability of the standard – existing sources c	2	1	2	0	0	0	0	$0
Notification of applicability of the standard – new sources c	2	1	2	0	0	0	0	$0
Notification of initial performance test c	2	1	2	3	6	0.3	0.6	$683
Report of initial test (including CMS performance evaluation and results) c	6	1	6	3	18	0.9	1.8	$2,049
Submit quality control plan for CMS c, f	2	1	2	0	0	0	0	$0
Submit startup, shutdown, malfunction plan c	2	1	2	0	0	0	0	$0
Report of monitoring exceedances and periods of noncompliance g	16	4	64	0	0	0	0	$0.00
Report of no excess emissions h	8	4	32	0	0	0	0	$0.00
Report of area source becoming major i	6	1	6	0	0	0	0	$0
Waiver application j	6	1	6	0	0	0	0	$0.00
Compliance status information report c	4	1	4	3	12	0.6	1.2	$1,366
Submit semiannual SSM reports k	2	2	4	0	0	0	0	$0
Submit immediate reports of inconsistent procedures monitored at each affected source h	2	1	2	0	0	0	0	$0
Submit a CMS summary report for HAP monitored at each affected source l	2	1	2	0	0	0	0	$0
Subtotal for Reporting Requirements					47			$4,667
4. Recordkeeping requirements
A. Familiarization with the regulatory requirements a	See 3A
B. Plan activities	N/A
C. Implement activities	See 4D, 4E
D. Develop record system c	40	1	40	0	0	0	0	$0
E. Time to enter information
a. Records of control device monitoring parameters:
- Continuously monitored parameters l, m	12	52	624	0	0	0	0	$0
- LDAR program reporting and recordkeeping – BLR l	311	1	311	0	0	0	0	$0
- LDAR program reporting and recordkeeping – WSR n	11	1	11	0	0	0	0	$0
- Wastewater parameters l, o	2	12	24	0	0	0	0	$0
- Records of operating parameters to meet D/F emission limit	1	52	52	5	260	13	26	$29,594.24
b. Record Information:
- Maintenance Vents	1	1	1	5	5	0.25	0.5	$569.12
- Pressure Relief Device - Releases to Atmosphere r	1	1	1	0	0	0	0	$0
- Heat Exchange System Recordkeeping	1	1	1	5	5	0.25	0.5	$569.12
F. Other recordkeeping activities
a. Maintain records of occurrence and duration of each SSM of process and control equipment h, p	2	8	16	0	0	0	0	$0
b. Maintain records of maintenance performed on air pollution control equipment h	2	4	8	0	0	0	0	$0
c. Maintain records of all action taken during periods of SSM that differ from the sources SSM plan h, q	2	1	2	0	0	0	0	$0
d. Maintain records of each period during which a CMS is malfunctioning or inoperative l	2	1	2	0	0	0	0	$0
e. Maintain records of result of all performance test and performance evaluations c	2	1	2	0	0	0	0	$0
f. Maintain all initial notification and compliance status notifications c	1	1	1	0	0	0	0	$0
G. Time for audits	N/A
H. Time to train personnel	8	1	8	3	24	1.2	2.4	$2,732
Subtotal for Recordkeeping Requirements					338			$33,464
Total Labor Burden and Costs (rounded) s					385			$38,100
Total Capital and O&M Cost (rounded) s								$3,440,000
Grand Total (rounded) s								$3,480,000
Assumptions:
a We have assumed that the average number of existing sources subject to the rule will be five. There will be no additional new sources per year that will become subject to the rule over the three-year period of this ICR. We assume that each respondent will have to familiarize with the regulatory requirements each year. We have assumed that one-third of the facilities would begin complying in year 2 and the remaining facilities in year 3. It is anticipated facilities will read the rule in year 1.
b This ICR uses the following labor rates for privately-owned sources: $161.34 for managerial, $101.24 for technical, and $45.17 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, May 2021, National Industry-Specific Occupational Employment and Wage Estimates for NAICS 325000 - Chemical Manufacturing. These rates have been adjusted using a Fringe Benefit Loading Rate of 1.5 and an Overhead and Profit Rate of 1.4 (Mean Hourly Rate * Fringe Benefit Loading Rate * Overhead and Profit Rate = Loaded Rate) 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 that this is a one-time-only cost. Records for one-time reporting activities must only be retained for five years. The five year period after these initial activities precedes the period covered by this ICR renewal.
d For all wet strength resins (WSR) facilities, as an alternative to implementing the standards for process vents, storage tanks, and wastewater, these facilities may elect to comply with the requirements of 40 CFR part 63, subpart H - leak detection and repair program for equipment leaks. Because it is more cost effective, we have assumed that all WSR facilities will choose to comply with the alternative standard. These facilities are not required to have the continuous monitoring systems (CMS) installed. Note that this item is not included in the incremental burden presented in this ICR.
e We have assumed that no facilities will have a physical or operational change.
f We have assumed that it will require one test each for wastewater and process vents. Note that this item is not included in the incremental burden presented in this ICR.
g We have assumed that one facility will have excess emissions. Note that this item is not included in the incremental burden presented in this ICR.
h We have assumed that there are five sources that are subject to this regulation, so the number of sources without excess emissions report is four. Note that this item is not included in the incremental burden presented in this ICR.
i We have assumed that no area sources are expected to become major sources.
j We have assumed that one facility will require a waiver. Note that this item is not included in the incremental burden presented in this ICR.
k We have assumed that it will take each respondent two hours to submit semiannual (SSM) reports. Also quarterly reporting may be reduced to semiannual reporting for sources that are in compliance for one year. The proposed amendments will remove the SSM exemption and the requirement to submit SSM reports will no longer apply three years after publication of the final rule. We have not included additional burden for SSM requirements in the incremental burden presented in this ICR.
l We have assumed that there are three basic liquid resins (BLR) manufacturing facilities. Note that this item is not included in the incremental burden presented in this ICR.
m We have assumed that these parameters will automatically be recorded with a data logger.
n We have assumed that there are four WSR facilities subject to the rule. Note that this item is not included in the incremental burden presented in this ICR.
o We have assumed that it will take two hours to record wastewater parameters during the monthly monitoring.
p We have assumed that startup, shutdown, and/or malfunction (SSM) will occur eight times per year for each facility. The proposed amendments will remove the SSM exemption and the SSM recordkeeping requirements will no longer apply three years after publication of the final rule. We have not included additional burden for SSM requirements in the incremental burden presented in this ICR.
q We have assumed that it will take two hours once per year for each facility to maintain records for one deviation from SSM plans. The proposed amendments will remove the SSM exemption and the SSM recordkeeping requirements will no longer apply three years after publication of the final rule. We have not included additional burden for SSM requirements in the incremental burden presented in this ICR.
r We have assumed that no respondents will have a relief valve discharge to the atmosphere during the three-year period of this ICR.
s Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 5: Table 4

Table 4: Summary of Annual Respondent Burden and Cost – Review of the NESHAP for Epoxy Resin and Non-Nylon Polyamide Production (40 CFR Part 63, Subpart W) (Proposed Rule)
Year	Technical Hours	Clerical Hours	Management Hours	Total Labor Hours	Labor Costs	Non-Labor (Annualized Capital/Startup and O&M) Costs	Total Costs
1	40	4	2	46	$4,550	$0	$4,550
2	153	15	8	176	$17,400	$1,850,000	$1,867,400
3	335	34	17	385	$38,100	$3,440,000	$3,478,100
Total	528	53	26	607	$60,050	$5,290,000	$5,350,050
Average	176	18	9	202	$20,000	$1,760,000	$1,780,000

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Sheet 6: Table 5

Table 5: Average Annual EPA Burden and Cost Year 1 – Review of the NESHAP for Epoxy Resin and Non-Nylon Polyamide Production (40 CFR Part 63, Subpart W) (Proposed Rule)
Activity	(A) EPA person- hours per occurrence	(B) No. of occurrences per plant per year	(C) EPA person- hours per plant per year (AxB)	(D) Plants 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) Cost, $ b
Report review										Labor Rates
Notification of construction/reconstruction and startup c	2	1	2	0	0	0	0	$0		Management	$69.04
Notification of physical and operational changes d	2	1	2	0	0	0	0	$0		Technical	$51.23
Notification of anticipated startup c	2	1	2	0	0	0	0	$0		Clerical	$27.73
Notification of actual startup c	2	1	2	0	0	0	0	$0
Notification of applicability of the standard new sources c	2	1	2	0	0	0	0	$0
Notification of initial performance test c	2	1	2	0	0	0	0	$0
Report of initial test c	8	1	8	0	0	0	0	$0
Startup, shutdown, malfunction plan c	4	1	4	0	0	0	0	$0
Quality control plan for CMS c	4	1	4	0	0	0	0	$0
Semiannual SSM reports e. f	4	2	8	0	0	0	0	$0
CMS summary report for HAP	4	1	4	0	0	0	0	$0
Immediate reports of inconsistent procedures	4	1	4	0	0	0	0	$0
Report of monitoring exceedances and periods of noncompliance g	8	4	32	0	0	0	0	$0
Report of no excess emission	2	4	8	0	0	0	0	$0
Compliance status information report c	2	1	2	0	0	0	0	$0
Waiver application h	8	1	8	0	0	0	0	$0
TOTAL (rounded) i					0			$0
Assumptions:
a We have assumed that the average number of existing sources subject to the rule will be five. There will be no additional new sources per year that will become subject to the rule over the three-year period of this ICR. We assume that each respondent will have to familiarize with the regulatory requirements each year. We have assumed that one-third of the facilities would begin complying in year 2 and the remaining facilities in year 3. It is anticipated facilities will read the rule in year 1.
b This ICR uses the following labor rates: $69.04 for managerial, $51.23 for technical, and $27.73 for clerical labor. These rates are from the Office of Personnel Management (OPM), 2021 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 this is a one-time-only cost.
d We have assumed that no facilities will conduct some form of physical or operational change.
e We have assumed that there are 5 sources that are subject to this regulation that report semiannually.
f We have assumed that it will take four hours to review semiannual reports.
g We have assumed that one facility will have excess emissions. Note that this item is not included in the incremental burden presented in this ICR.
h We have assumed that one facility will request a waiver. Note that this item is not included in the incremental burden presented in this ICR.
i Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 7: Table 6

Table 6: Average Annual EPA Burden and Cost Year 2 – Review of the NESHAP for Epoxy Resin and Non-Nylon Polyamide Production (40 CFR Part 63, Subpart W) (Proposed Rule)
Activity	(A) EPA person- hours per occurrence	(B) No. of occurrences per plant per year	(C) EPA person- hours per plant per year (AxB)	(D) Plants 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) Cost, $ b
Report review										Labor Rates
Notification of construction/reconstruction and startup c	2	1	2	0	0	0	0	$0		Management	$69.04
Notification of physical and operational changes d	2	1	2	0	0	0	0	$0		Technical	$51.23
Notification of anticipated startup c	2	1	2	0	0	0	0	$0		Clerical	$27.73
Notification of actual startup c	2	1	2	0	0	0	0	$0
Notification of applicability of the standard new sources c	2	1	2	0	0	0	0	$0
Notification of initial performance test c	2	1	2	2	4	0.2	0.4	229.82
Report of initial test c	8	1	8	2	16	0.8	1.6	919.28
Startup, shutdown, malfunction plan c	4	1	4	0	0	0	0	$0
Quality control plan for CMS c	4	1	4	0	0	0	0	$0
Semiannual SSM reports e. f	4	2	8	0	0	0	0	$0
CMS summary report for HAP	4	1	4	0	0	0	0	$0
Immediate reports of inconsistent procedures	4	1	4	0	0	0	0	$0
Report of monitoring exceedances and periods of noncompliance g	8	4	32	0	0	0	0	$0
Report of no excess emission	2	4	8	0	0	0	0	$0
Compliance status information report c	2	1	2	2	4	0.2	0.4	$229.82
Waiver application h	8	1	8	0	0	0	0	$0.00
TOTAL (rounded) i					28			$1,380
Assumptions:
a We have assumed that the average number of existing sources subject to the rule will be five. There will be no additional new sources per year that will become subject to the rule over the three-year period of this ICR. We assume that each respondent will have to familiarize with the regulatory requirements each year. We have assumed that one-third of the facilities would begin complying in year 2 and the remaining facilities in year 3. It is anticipated facilities will read the rule in year 1.
b This ICR uses the following labor rates: $69.04 for managerial, $51.23 for technical, and $27.73 for clerical labor. These rates are from the Office of Personnel Management (OPM), 2021 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 this is a one-time-only cost.
d We have assumed that no facilities will conduct some form of physical or operational change.
e We have assumed that there are 5 sources that are subject to this regulation that report semiannually.
f We have assumed that it will take four hours to review semiannual reports.
g We have assumed that one facility will have excess emissions. Note that this item is not included in the incremental burden presented in this ICR.
h We have assumed that one facility will request a waiver. Note that this item is not included in the incremental burden presented in this ICR.
i Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 8: Table 7

Table 7: Average Annual EPA Burden and Cost Year 3 – Review of the NESHAP for Epoxy Resin and Non-Nylon Polyamide Production (40 CFR Part 63, Subpart W) (Proposed Rule)
Activity	(A) EPA person- hours per occurrence	(B) No. of occurrences per plant per year	(C) EPA person- hours per plant per year (AxB)	(D) Plants 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) Cost, $ b
Report review										Labor Rates
Notification of construction/reconstruction and startup c	2	1	2	0	0	0	0	$0		Management	$69.04
Notification of physical and operational changes d	2	1	2	0	0	0	0	$0		Technical	$51.23
Notification of anticipated startup c	2	1	2	0	0	0	0	$0		Clerical	$27.73
Notification of actual startup c	2	1	2	0	0	0	0	$0
Notification of applicability of the standard new sources c	2	1	2	0	0	0	0	$0
Notification of initial performance test c	2	1	2	3	6	0.3	0.6	$344.73
Report of initial test c	8	1	8	3	24	1.2	2.4	$1,378.92
Startup, shutdown, malfunction plan c	4	1	4	0	0	0	0	$0
Quality control plan for CMS c	4	1	4	0	0	0	0	$0
Semiannual SSM reports e. f	4	2	8	0	0	0	0	$0
CMS summary report for HAP	4	1	4	0	0	0	0	$0
Immediate reports of inconsistent procedures	4	1	4	0	0	0	0	$0
Report of monitoring exceedances and periods of noncompliance g	8	4	32	0	0	0	0	$0
Report of no excess emission	2	4	8	0	0	0	0	$0
Compliance status information report c	2	1	2	3	6	0.3	0.6	$344.73
Waiver application h	8	1	8	0	0	0	0	$0
TOTAL (rounded) i					41			$2,070
Assumptions:
a We have assumed that the average number of existing sources subject to the rule will be five. There will be no additional new sources per year that will become subject to the rule over the three-year period of this ICR. We assume that each respondent will have to familiarize with the regulatory requirements each year. We have assumed that one-third of the facilities would begin complying in year 2 and the remaining facilities in year 3. It is anticipated facilities will read the rule in year 1.
b This ICR uses the following labor rates: $69.04 for managerial, $51.23 for technical, and $27.73 for clerical labor. These rates are from the Office of Personnel Management (OPM), 2021 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 this is a one-time-only cost.
d We have assumed that no facilities will conduct some form of physical or operational change.
e We have assumed that there are 5 sources that are subject to this regulation that report semiannually.
f We have assumed that it will take four hours to review semiannual reports.
g We have assumed that one facility will have excess emissions. Note that this item is not included in the incremental burden presented in this ICR.
h We have assumed that one facility will request a waiver. Note that this item is not included in the incremental burden presented in this ICR.
i Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 9: Table 8

Table 8: Summary of Average Annual EPA Burden and Cost – Review of the NESHAP for Epoxy Resin and Non-Nylon Polyamide Production (40 CFR Part 63, Subpart W) (Proposed Rule)
Year	Technical Hours	Clerical Hours	Management Hours	Total Labor Hours	Labor Costs	Non-Labor (Annualized Capital/Startup and O&M) Costs	Total Costs
1	0	0	0	0	$0	$0	$0
2	24	2	1	28	$1,380	$0	$1,380
3	36	4	2	41	$2,070	$0	$2,070
Total	60	6	3	69	$3,450	$0	$3,450
Average	20	2	1	23	$1,150	$0	$1,150

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Sheet 10: Additional Tables

								Total Annual Responses
Number of Respondents								(A)	(B)	(C)	(D)	(E)
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports					Information Collection Activity	Number of Respondents 1	Number of Responses	Number of Existing Respondents That Keep Records But Do Not Submit Reports	Total Annual Responses E=(BxC)+D
	(A)	(B)	(C)	(D)	(E)			Notification of physical and operational changes	0	1	0	0
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)			Report of monitoring exceedances and periods of noncompliance	0	4	0	0
1	0	5	0	0	5			Report of no excess emissions	0	4	0	0
2	0	5	0	0	5			Waiver application	0	1	0	0
3	0	5	0	0	5			SSM report	0	2	0	0
Average	0	5	0	0	5			Immediate report of inconsistent procedures	0	1	0	0
1 New respondents include sources with constructed, reconstructed and modified affected facilities.								CMS summary report	0	1	0	0
								Notification of initial performance test	1.67	1	0	1.67
								Report of initial test	1.67	1	0	1.67
								Compliance status information report	1.67	1	0	1.67
											Total	5
								1 We have assumed there are five existing respondents that will submit the notifications and reports associated with the incremental burden of the proposed amendments listed above, or an overall average of 1.67 respondents per year.
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)		1998 CEPCI CE Index	389.5
Continuous Monitoring System a, b	$4,544	0	$0	$5,453	0	$0		2021 CEPCI CE Index	708
PRD Requirements	$26,545	5	$132,724	$6,762	5	$33,809
Maintenance Vent Requirements	N/A	N/A	N/A	$455	5	$2,277
Control Device and testing to meet D/F Limit	$560,000	5	$2,800,000	$325,000	5	$1,625,000
Heat Exchange Systems	$3,720	5	$18,600	$1,102	5	$5,510
Total c			$2,950,000			$1,670,000
a The continuous monitoring system is not included in the incremental burden imposed by the proposed amendments to 40 CFR 63, Subpart W.
b Capital/startup costs and O&M costs have been updated from 1998 dollars to 2021 dollars using the CEPCI CE Index.
c Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.