Supplementary Doc- Burden Tables

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Overview

Summary
Table 1
Table 2
Capital O&M
Respondents
Responses

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Sheet 1: Summary

ICR Summary Information
Hours Per Response	269
Number of Respondents	19
Total Estimated Burden Hours	13,200
Total Estimated Costs	$2,150,000
Annualized Capital O&M	$339,000
Form Number	N/A

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Sheet 2: Table 1

Table 1: Annual Respondent Burden and Cost – NESHAP for Pesticide Active Ingredient Production (40 CFR Part 63, Subpart MMM) (Renewal)
Burden item	A	B	C	D	E	F	G	H						Source Type	No.
	Person-hours per occurrence	Annual occurrences per respondent	Person-hours per respondent per year (AxB)	Respondents per year a	Technical hours per year (CxD)	Management hours per year (Ex0.05)	Clerical hours per year (Ex0.10)	Annual Cost ($) b						Existing	19
1. Applications	N/A													Modified	0
2. Surveys and studies	N/A													New	1
3. Reporting requirements
A. Familiarization with Regulatory Requirements	2	1	2	19	38	2	4	$5,985.25		Labor Rates
B. Required activities										Managerial	$172.41
Performance evaluation test (CMS certification)	13	6	78	1	78	4	8	$12,286		Technical	$141.75
C. Create information	See 3B									Clerical	$71.36
D. Gather existing information	See 3E
E. Write report
Notification and application of construction/reconstruction c	2	1	2	0	0	0	0	$0
Notification of applicability c	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 process changes d	8	1	8	1	8	0.4	0.8	$1,260.05
Pre-compliance report c	40	1	40	1	40	2	4	$6,300
Notification of initial performance test c	2	1	2	1	2	0.10	0.20	$315
Notification of repeat performance test c	2	1	2	0.1	0.10	0.01	0.01	$16
Notification of initial CMS performance evaluation c	2	1	2	1	2	0	0	$315
CMS evaluation with performance test c, e	80	1	80	0.9	72	4	7	$11,340
CMS evaluation without performance test c, f	120	1	120	0.1	12	1	1	$1,890
Periodic reporting
Semiannual report g	8	2	16	17	272	13.6	27.2	$42,841.77
Quarterly report h	24	4	96	2	192	9.6	19.2	$30,241.25
Emissions averaging plan i	40	1	40	2	80	4	8	$12,600.52
PRD reportingk	5.5	2	11	19	209	10.5	20.9	$32,918.86
LDAR reportingk	94	2	188	19	3,572	178.6	357.2	$562,613.22
Subtotal for Reporting Requirements					5,264			$720,923
4. Recordkeeping requirements
A. Familiarization with Regulatory Requirements	See 3A
B. Plan activities	N/A
C. Implement activities	N/A
D. Develop record system c	40	1	40	1	40	2	4	$6,300
E. Develop QA/QC plan for CMS c	40	1	40	1	40	2	4	$6,300
F. Time to enter information
Records of excess emissions	1.5	52	78	1	78	4	8	$12,286
Records of CMS data
Record continuously monitored parameters j	1	320	320	19	6,080	304	608	$957,639.52
Enter/verify information for periodic report	16	2	32	19	608	30.4	60.8	$95,763.95
G. CMS calibration c	48	1	48	1	48	2	5	$7,560
H. Train personnel c	40	1	40	1	40	2	4	$6,300
I. Audits	N/A
Subtotal for Recordkeeping Requirements					7,974			$1,092,000
TOTAL ANNUAL BURDEN AND COST (ROUNDED)l					13,200			$1,810,000
TOTAL CAPITAL AND O&M COST (rounded)l								$339,000
GRAND TOTAL (rounded)l								$2,150,000
								269		hr/response
a On average, EPA estimates 19 existing sources will be subject to the NESHAP. No new sources will become subject to the standard over the three-year period of this ICR. However, based on comments received from Corteva, we assume one existing source per year will install a new process unit.
b This ICR uses the following labor rates: Managerial $172.41 ($82.10+ 110%); Technical $141.75 ($67.50 + 110%); and Clerical $71.36 ($33.98 + 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, December 2023, “Table 2. Civilian workers by occupational and industry group.” The rates are from column 1, “Total compensation.” The rates are 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 Applies to new or reconstructed sources only. However, based on comments received from Corteva, we assume one existing source per year will install a new process unit and would be required to conduct certain activities, including submit an updated pre-compliance report, notifications of initial performance test or performance evaluation, update record management systems, and develop of a QA/QC plan for CMS. We assume 5 percent of new sources would be required to conduct a repeat performance test.
d EPA assumes 5 percent of existing facilities (19 x 0.05 = 1, after rounding) will implement process changes.
e EPA assumes 90 percent of new sources will comply by conducting performance testing.
f EPA assumes 10 percent of new sources will comply by submitting engineering calculations, designing calculations, and CMS performance evaluation results.
g EPA assumes 90 percent of sources (19 x 0.9 = 17, after rounding) will have no exceedances and periods of noncompliance; therefore, they will submit periodic reports on a semiannual basis.
h EPA assumes 10 percent of sources (19 x 0.1 = 2, after rounding) will have exceedances and periods of noncompliance; therefore, they will submit periodic reports on a quarterly basis.
i EPA assumes 10 percent of existing sources will comply with emissions averaging requirements. New sources are not allowed to use emissions averaging.
j EPA assumes it will take 1 hour, 320 times per year, to record continuously monitored parameter data.
k Pressure Relief Device (PRD) reporting and Leak Detection and Repair (LDAR) reporting are submitted with the semiannual report.
l 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 Pesticide Active Ingredient Production (40 CFR Part 63, Subpart MMM) (Renewal)
Burden item	A	B	C	D	E	F	G	H
	EPA person-hours per occurrence	Annual occurrences per respondent	EPA person-hours per respondent per year (AxB)	Respondents per year a	Technical hours per year (CxD)	Management hours per year (Ex0.05)	Clerical hours per year (Ex0.10)	Annual cost ($) b
Initial performance test	40	1	40	1	40	2	4	$2,560
Repeat performance test c	40	1	40	0.1	2	0	0	$128
Performance evaluation test (CMS certification) d	2	6	12	0.1	1	0	0	$77
Report review										Labor Rates
Notification of construction/reconstruction	2	1	2	0	0	0	0	$0		Managerial	$76.91
Notification of applicability	2	1	2	0	0	0	0	$0		Technical	$57.07
Notification of anticipated startup	2	1	2	0	0	0	0	$0		Clerical	$30.88
Notification of actual startup	2	1	2	0	0	0	0	$0
Notification of process changes e	8	1	8	1	8	0.4	0.8	$512.03
Pre-compliance plan	4	1	4	1	4	0	0	$256
Notification of initial performance test	2	1	2	1	2	0	0	$128
Notification of initial CMS performance evaluation	2	1	2	1	2	0	0	$128
CMS evaluation with performance test f	40	1	40	0.9	36	2	4	$2,304
CMS evaluation without performance test g	40	1	40	0.1	4	0	0	$256
Semiannual report h	2	2	4	17	68	3.4	6.8	$4,352.24
Quarterly report i	8	4	32	2	64	3.2	6.4	$4,096.22
Emissions averaging plan j	20	1	20	2	40	2	4	$2,560.14
TOTAL ANNUAL BURDEN AND COST (ROUNDED)k					312			$17,400
a On average, EPA estimates 19 existing sources will be subject to the NESHAP. No new sources will become subject to the standard over the three-year period of this ICR. However, based on comments received from Corteva, we assume one existing source per year will install a new process unit.
b This cost is based on the average hourly labor rate as follows: Managerial $76.91 (GS-13, Step 5, $48.07 + 60%); Technical $57.07 (GS-12, Step 1, $35.67 + 60%); and Clerical $30.88 (GS-6, Step 3, $19.30+ 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), 2024 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 EPA assumes five percent of new sources will repeat performance testing.
d EPA assumes Agency personnel will attend ten percent of evaluation tests.
e EPA assumes 5 percent of existing facilities (19 x 0.05 = 1, after rounding) will implement process changes.
f EPA assumes 90 percent of new sources will comply by conducting performance testing.
g EPA assumes 10 percent of new sources will comply by submitting engineering calculations, designing calculations, and CMS performance evaluation results.
h EPA assumes 90 percent of sources (19 x 0.9 = 17, after rounding) will have no exceedances and periods of noncompliance; therefore, they will submit periodic reports on a semiannual basis.
i EPA assumes 10 percent of sources (19 x 0.1 = 2, after rounding) will have exceedances and periods of noncompliance; therefore, they will submit periodic reports on a quarterly basis.
j EPA assumes 10 percent of existing sources will comply with emissions averaging requirements. New sources are not allowed to use emissions averaging.
k 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	Total O&M, (E X F)
PRD Electronic Indicators b	$11,632	1	$11,632	$2,825	19	$53,675
Performance Tests	$52,200	1	$52,200	$0	0	$0
Process Vents CMSc	$15,920	1	$15,920	$1,220	19	$23,180
Wastewater CMSd	$10,690	1	$10,690	$9,038	19	$171,722
Total (rounded)			$90,400			$249,000	TOTAL	$339,000
a On average, EPA estimates 19 existing sources will be subject to the NESHAP and no new sources will become subject to the standard over the three-year period of this ICR. However, based on previous comments received from Corteva, we assume one existing source per year will install a new process unit.
b Based on previous comments received from Corteva, we assume a cost of $2,825 annually per respondent for annual PRD monitoring.
c Based on previous comments received from Corteva, we assume approximately 10 hours of technical labor for programming time, correct instrumentation, and calibrations, or $1,220 per respondent annually.
d Based on previous comments received from Corteva, we assume a cost of $9,038 annually per respondent for calibration and maintenance for the treatment device and associated control devices and operating parameters.

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Sheet 5: 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	1	19	0	1	19
2	1	19	0	1	19
3	1	19	0	1	19
Average	1	19	0	1	19
a New respondents include sources with constructed, reconstructed and modified affected facilities.

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Sheet 6: Responses

Total Annual Responses
(A) Information Collection Activity	(B) Number of Respondents	(C) Number of Responses	(D) Number of Existing Respondents That Keep Records But Do Not Submit Reports	(E) Total Annual Responses E=(BxC)+D
Notification of construction/reconstruction	0	1	0	0
Notification of applicability	0	1	0	0
Notification of anticipated startup	0	1	0	0
Notification of actual startup	0	1	0	0
Notification of process changes	1	1	0	1
Pre-compliance report	1	1	0	1
Notification of initial performance test	1	1	0	1
Notification of initial CMS performance evaluation	1	1	0	1
CMS evaluation with performance test	0.9	1	0	0.9
CMS evaluation without performance test	0.1	1	0	0.1
Semiannual report	17	2	0	34
Quarterly report	2	4	0	8
Emissions averaging plan	2	1	0	2
			Total	49