Burden Tables

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Overview

Table 1
Table 2
O&M

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Sheet 1: Table 1

Table 1: Annual Respondent Burden and Cost – Air Emission Standards for Tanks, Surface Impoundment and Containers (40 CFR Part 264, Subpart CC, and 40 CFR Part 265, Subpart CC) (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. Survey and Studies	N/A									Managerial	$163.17
3. Reporting requirements										Technical	$130.28
A. Familiarize with regulatory requirements c	4	1	4	6,760	27,040	1,352	2,704	$3,921,056.88		Clerical	$65.71
B. Required activities	N/A
C. Create information	N/A
D. Gather existing information	1	1	1	6,760	6,760	338	676	$980,264.22
E. Write report
i. Annual project report d	1	1	1	1	1	0.05	0.1	$145.01
ii. Final project report d	1	0	0	1	0	0	0	$0
iii. Report required by 264.1080(f)(2)(viii)(F) d	1	0	0	1	0	0	0	$0
iv. Semiannual report e	1	2	2	35	70	3.5	7.0	$10,150.67
v. Report to EOA within 15 calendar days of waste determination exceedance f	1	2	2	68	136	6.8	14	$19,721.29
vi. Notify EPA/WVDEP 60 days in advance for performance test of incinerator d	1	0	0	1	0	0	0	$0
vii. Performance test results report for Sistersville Plant d	1	0	0	1	0	0	0	$0
viii. Notification regarding hydrogen peroxide management g	1	1	1	1	1	0.05	0.1	$145.01
ix. Notify RA 30 days in advance of any gap measurements to be taken h	1	1	1	1,352	1,352	68	135	$196,052.84
x. Notify RA 30 days in advance of filling, or refilling tank i	1	1	1	676	676	34	68	$98,026.42
Reporting Subtotal					41,441			$5,225,562
4. Recordkeeping requirements
A. Recordkeeping for Sistersville, WV plant j
i. Prepare and record documentation that air emission control present undue hazard	1	1	1	1	1	0.05	0.1	$145.01
ii. Information going into annual report
(1) Emission analysis	0.33	1	0.33	1	0.33	0.02	0.03	$47.85
(2) Plant performance evaluation	0.33	1	0.33	1	0.33	0.02	0.03	$47.85
(3) Description of anticipated problems	0.33	1	0.33	1	0.33	0.02	0.03	$47.85
iii. Startup/shutdown plan	1	0	0	1	0	0	0	$0
iv. Records of defect repair	0.5	2	1	1	1	0.05	0.1	$145.01
v. Records of the inspection and repair of the closed-vent system	0.5	2	1	1	1	0.05	0.1	$145.01
vi. Record dates and time that capper unit and condenser are operating	0.25	365	91.25	1	91	4.6	9.1	$13,232.12
vii. Record amount of methanol generated and recovered; and condenser temperature	0.25	365	91.25	1	91	4.6	9.1	$13,232.12
viii. Record of amount of methanol directed to reuse, recovery, thermal recovery/treatment and bio-treatment	0.25	365	91.25	1	91	4.6	9.1	$13,232.12
B. Familiarize with regulatory requirements c	4	1	4	6,760	27,040	1,352	2,704	$3,921,056.88
C. Plan activities k	16	1	16	6,760	108,160	5,408	10,816	$15,684,227.52
D. Implement activities
i. Waste determination for VO concentration at a point of origin
(1) Waste determination once every 12 months	2	1	2	6,760	13,520	676	1,352	$1,960,528.44
ii. Waste determination for treated hazardous waste
(1) Waste determination for batch process once every 12 months	2	1	2	6,760	13,520	676	1,352	$1,960,528.44
iii. Inspect and monitor each closed vent system l	0.08	365	29.2	3,380	98,696	4,935	9,870	$14,311,857.61
iv. Write and implement an inspection plan and place in facility inspection plan	4	1	4	0	0	0	0	$0
v. Inspect all coverings and monitor for initial detectable emissions, initial operation, using Method 21
(1) Tanks	4	1	4	0	0	0	0	$0
(2) Surface impoundments	5	1	5	0	0	0	0	$0
(3) Containers	2	1	2	0	0	0	0	$0
vi. Inspect all coverings and monitor for detectable emissions at least once every 6 months using Method 21
(1) Tanks (includes Method 27- transportation vehicles)	4	2	8	6,760	54,080	2,704	5,408	$7,842,113.76
(2) Surface impoundments	5	2	10	119	1,190	60	119	$172,561.31
(3) Containers	2	2	4	6,760	27,040	1,352	2,704	$3,921,056.88
vii. Owner/operator writes and implements plan with schedule to inspect unsafe covers	1	1	1	0	0	0	0	$0
viii. Owner/operator writes and implements plan with schedule to inspect difficult to inspect covers	1	1	1	0	0	0	0	$0
ix. Secondary seal inspection once a year	4	1	4	6,760	27,040	1,352	2,704	$3,921,056.88
x. Primary seal inspection once every 5 years m	4	1	4	1,352	5,408	270	541	$784,211.38
xi. General standards, record ID number of BIF, or incinerator used to treat waste	0.25	1	0.25	0	0	0	0	$0
xii. Tanks and unsafe covers, record list of ID numbers for tanks with unsafe covers explain why it’s unsafe and plan to inspect and monitor each cover	0.25	1	0.25	0	0	0	0	$0
xiii. Tanks with difficult to inspect covers, record list of ID numbers, explain why difficult and plan to inspect and monitor each cover	0.3	1	0.3	0	0	0	0	$0
E. Develop record system	16	1	16	0	0	0	0	$0
F. Time to enter information
i. Record each cover installed on a tank and certifies to its specifications	0.25	1	0.25	0	0	0	0	$0
ii. Record each floating membrane installed on a surface impoundment and certifies to its Specifications	0.25	1	0.25	0	0	0	0	$0
iii. Record each enclosure used to control air emissions and certifies to its specifications	0.25	1	0.25	0	0	0	0	$0
iv. Records for each closed vent and control device it is designed to operate at the performance level for tank, surface impoundments, or container	0.25	1	0.25	0	0	0	0	$0
v. Records all Method 27 tests performed by owner/operator for each container	0.5	1	0.5	6,760	3,380	169	338	$490,132.11
vi. Records all visual inspections for each tank, surface impoundment and container, including covers	1	1	1	6,760	6,760	338	676	$980,264.22
Tanks with air emission controls:
vii. Records date of each attempts to repair leak, repair methods applied and date of successful repair	0.5	2	1	6,760	6,760	338	676	$980,264.22
viii. Records all continuous monitoring	0.25	365	91.25	676	61,685	3,084	6,169	$8,944,911.01
ix. Records management of carbon removed from a carbon absorption system	0.5	2	1	3,380	3,380	169	338	$490,132.11
x. Records date and time of each sample	0.25	2	0.5	6,760	3,380	169	338	$490,132.11
xi. Records results of each sample	0.25	2	0.5	6,760	3,380	169	338	$490,132.11
xii. Records tank dimensions and design capacity	0.3	1	0.3	0	0	0	0	$0
Tanks with alternative emission control (floating roofs):
xiii. Records in the facility operating plan of the internal floating roof	0.25	1	0.25	0	0	0	0	$0
xiv. Record the equipment design and certifies that it meet applicable requirements	0.25	1	0.25	0	0	0	0	$0
xv. Record each inspection, the tank, date, and what components were inspected	0.25	2	0.5	6,760	3,380	169	338	$490,132.11
(1) If defects found, identify the tank and describe the repairs that were made	0.25	2	0.5	6,760	3,380	169	338	$490,132.11
xvi. Record in the facility operating plan the external floating roof	0.25	1	0.25	0	0	0	0	$0
xvii. Record the equipment design and certifies that it meets applicable requirements	0.25	1	0.25	0	0	0	0	$0
xviii. Record gap measurements of the tank, date of inspection, raw data and calculations	0.25	1	0.25	6,760	1,690	85	169	$245,066.06
(1) If defects found, record the tank, date tank was emptied, or repairs make and the nature of repair	0.25	1	0.25	6,760	1,690	85	169	$245,066.06
xix. Continuous monitoring inspections
(1) Closed-vent systems	4	1	4	6,760	27,040	1,352	2,704	$3,921,056.88
xx. Roof inspections/gap measurements:
(1) Secondary seal inspection (once a year)	4	1	4	6,760	27,040	1,352	2,704	$3,921,056.88
(2) Primary seal inspection (once every 5 years) n	4	0.2	0.8	1,352	1,082	54	108	$156,842.28
G. Train personnel
i. Waste determination methods	8	1	8	6,760	54,080	2,704	5,408	$7,842,113.76
ii. Control equipment inspection and monitor	8	1	8	6,760	54,080	2,704	5,408	$7,842,113.76
H. Audits	N/A
Recordkeeping Subtotal					733,882			$92,539,022		hours/response
Total Labor Burden and Costs (Rounded) o					775,000			$97,800,000		114
Total Capital and O&M Costs (Rounded) o								$13,500,000
Grand Total (Rounded) o								$111,000,000
Assumptions:
a We have assumed that the average number of respondents that will be subject to this rule will be 6,760. There will be no new additional sources during the three year period of this ICR.
b This ICR uses the following labor rates: $163.17 per hour for Executive, Administrative, and Managerial labor; $130.28 per hour for Technical labor, and $65.71 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2023, “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 have assumed that all of the respondents will familiarize with the regulatory requirements each year.
d We have assumed that only the Sistersville, WV Plant XL Project will be reporting.
e We have assumed that 0.5 percent of respondents will report control devices malfunction, resulting in exceedance annually (0.5% x 6,760 = 34), along with the Sistersville Plant XL project (1) always reports semiannually for a total of 34 + 1 = 35 semiannual reports.
f We have assumed that 1 percent of waste determination will result in exceedance annually (1% x 6,760 = 67.6, rounded to 68).
g We have assumed that only one facility currently uses the exemption regarding hydrogen peroxide management located at 40 CFR 264.1080(d) and 40 CFR 265.1080(d).
h We have assumed that 20 percent of the tank roofs will be inspected each year (external roof) (20% x 6,760 = 1,352).
i We have assumed that 10 percent of respondents will empty and refill a tank (internal floating roof) (10% x 6,760 = 676).
j We assume recordkeeping only for the Sistersville, WV Plant XL Project.
k We have assumed that it will take each respondent sixteen hours once per year to plan activities.
l We have assumed that 50 percent of respondent will be required on a daily basis to inspect and monitor each closed vent system (50% x 6,760 = 3,380).
m We have assumed that 20 percent of respondents will take 4 hours once every five years to complete the primary seal inspection. (20% x 6,760 = 1,352).
n We have assumed that 20 percent of tanks with alternative emission controls (floating roofs) will each take 4 hours 0.2 times per year, which equates to once every 5 years, to complete the primary seal inspection. (20% x 6,760 = 1,352).
o Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 2: Table 2

Table 2: Average Annual EPA Burden and Cost – Air Emission Standards for Tanks, Surface Impoundment and Containers (40 CFR Part 264, Subpart CC, and 40 CFR Part 265, Subpart CC) (Renewal)
Activity	(A) EPA person hours per occurrence	(B) No. of occurrences per plant per year	(C) EPA person hours per respondent 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
A. Review report										Labor Rates
1. Waste exceedance reports c	4	1	4	68	272	14	27	$16,628.18		Managerial	$73.46
2. Control device exceedance reports d	4	2	8	35	280	14	28	$17,117.24		Technical	$54.51
3. Notification reports e	1	1	1	2,029	2,029	101	203	$124,038.86		Clerical	$29.50
4. Annual project report f	4	1	4	1	4	0.2	0.4	$244.53
B. Review Records
1. Select site and review permit g	8	1	8	520	4,160	208	416	$254,313.28
TOTAL (Rounded) h					7,760			$412,000
Assumptions:
a We have assumed that the average number of respondents that will be subject to this rule will be 6,760. There will be no new additional sources during the next three years of this ICR.
b The cost is based on the following labor rate which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses. Managerial rates of $73.46 (GS-13, Step 5, $45.91 × 1.6), Technical rate of $54.51 (GS-12, Step 1, $34.07 × 1.6), and Clerical rate of $29.50 (GS-6, Step 3, $18.44 × 1.6). These rates are from the Office of Personnel Management (OPM), 2023 General Schedule, which excludes locality, rates of pay.
c Annual responses assume 1 percent of waste determination results in an exceedance (1% x 6,760 = 67.6. rounded to 68).
d Semiannual responses assumes 0.5% of control devices malfunction resulting in an exceedance (0.5% x 6,760 = 34) plus the Sistersville, WV Plant. (34 + 1 = 35)
e We have assumed that 10 percent of internal floating roof respondents (10% x 6,760 = 676), plus 20% of external roof respondents (20% x 6,760 = 1,352), and one facility using hydrogen peroxide exemption (676 + 1,352 + 1 = 2,029) will submit notification reports.
f We have assumed that the Sisterville Plant will submit an annual project report.
g We have assumed that it will take respondents 8 hours once per year to review selected sites and review permit records.
h Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: 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)
Organic emission control equipment	$0	$0	$0	$2,000	6,760	$13,520,000
Total			$0			$13,500,000
	Note: Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
Number of Respondents							Total Annual Responses
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports				(A)	(B)	(C)	(D)	(E)
	(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
Year	Number of New Respondents a	Number of Existing Respondents b	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)		Notification report for internal and external floating roof	2,028	1	0	2,028
1	0	2,132	4,628	0	6,760		Notification of hydrogen peroxide management exemption	1	1	0	1
2	0	2,132	4,628	0	6,760		Semiannual report	35	2	0	70
3	0	2,132	4,628	0	6,760		Annual exceedance report	68	1	0	68
Average	0	2,132	4,628	0	6,760		Annual Sisterville Plant project report	1	1	0	1
							Recordkeeping requirements	0	0	4,628	4,628
							Total				6,796
							Note: The Sisterville Plant is counted twice in the # of Respondents column.