Burden Tables

1156t16.xlsx

NSPS for Synthetic Fiber Production Facilities (40 CFR Part 60, Subpart HHH) (Renewal)

Burden Tables

OMB: 2060-0059

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Overview

Summary
Table 1
Table 2
Capital O&M
Respondents
Responses


Sheet 1: Summary

ICR Summary Information
Hours Per Response 34
Number of Respondents 22
Total Estimated Burden Hours 1,880
Total Estimated Costs $510,000
Annualized Capital O&M $252,000
Form Number Not Applicable

Sheet 2: Table 1

Table 1: Annual Respondent Burden and Cost – NSPS for Synthetic Fiber Production Facilities (40 CFR Part 60, Subpart HHH) (Renewal)






















Burden item (A) (B) (C) (D) (E) (F) (G) (H)


Person-hours per occurrence No. of occurrences per respondent per year Person hours per respondent per year (AxB) Respondents per yeara Technical person-hours per year (CxD) Management person-hours per year (Ex0.05) Clerical person-hours per year (Ex0.1) Cost, $b


1. Applications N/A







Labor Rates
2. Survey and Studies N/A







Management $172.41
3. Reporting Requirements








Technical $141.75
A. Familiarize with rule requirements 1 1 1 22 22 1.1 2.2 $3,465.14
Clerical $71.36
B. Required activities










Initial performance test 72 1 72 0 0 0 0 $0


Repeat performance test c 72 0.2 14.4 0 0 0 0 $0


C. Create information See 3B









D. Gather existing information See 3B









E. Write report










New Sources










Notification of construction/ reconstruction d 2 1 2 0 0 0 0 $0


Notification of actual startup d 2 1 2 0 0 0 0 $0


Notification of initial performance test d 2 1 2 0 0 0 0 $0


Notification of demonstration of CMS d 2 1 2 0 0 0 0 $0


Report of initial performance test d See 3B









Existing Sources










Quarterly report of VOCs emission exceedances e 8 0.5 4 22 88 4.4 8.8 $13,860.57


Semiannual report of no exceedances f 2 2 4 22 88 4.4 8.8 $13,860.57


Notification of limit exceedance for extruded fiber g 2 1 2 0 0 0 0 $0


Subtotal for Reporting Requirements



228 $31,186


4. Recordkeeping requirements










A. Familiarize with rule requirements See 3A









B. Plan activities See 4C









C. Implement activities See 3B









D. Develop record system See 4E








E. Time to enter information










Records of operating parameters h 0.25 250 62.5 22 1375 68.75 137.5 $216,571.44


Records of monthly VOC emission i 0.25 12 3 22 66 3.3 6.6 $10,395.43


F. Time to train personnel N/A









G. Time for audits N/A









Subtotal for Recordkeeping Requirements



1,657 $226,967


TOTAL LABOR BURDEN AND COST(roundedj)



1,880 $258,000
# Hours per response
Total CAPITAL AND O&M Costs (rounded)j






$252,000
34
Grand Total (rounded)j






$510,000














Assumptions:










a We have assumed that the average number of respondents that will be subject to the rule will be 22. There will be no additional new source that will become subject to the rule over the three-year period of this ICR.


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 We have assumed that 20 percent of initial performance tests will be repeated.


d We have assumed that there will be no new sources over the three-year period of this ICR.


e We have assumed that each respondent will submit one quarterly report every other year due to excess of volatile organic compounds (VOCs) emissions.


f Semiannual reports are required of all respondents.


g We have assumed that there are no existing solvent-spun synthetic fiber producing facility subject to the exemption under section 60.600(a) that would have exceeded the annual requirement of 500 mg. Therefore, no existing solvent-spun synthetic fiber producing facility will submit a notification of exceeding the limits over the three-year period of the ICR.


h We have assumed that respondents will enter information on records of operating parameters 250 days per year.


i Respondents are required to conduct monthly calculation of the 6 months VOC average emission which is considered a performance test. Respondents will have to determine this value by calculating the VOC emissions per unit of mass solvent feed from each affected facility for the current and proceeding five consecutive calendar months.


j Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.



Sheet 3: Table 2

Table 2: Average Annual EPA Burden and Cost – NSPS for Synthetic Fiber Production Facilities (40 CFR Part 60, Subpart HHH) (Renewal)














Activity (A) (B) (C) (D) (E) (F) (G) (H)


EPA person-hours per occurrence No. of occurrences per plant per year EPA person hours per plant per year (AxB) Plants per yeara Technical person-hours per year (CxD) Management person-hours per year (Ex0.05) Clerical person-hours per year (Ex0.1) Cost, $b


Required Activities








Labor Rates
New Plant








Management $76.91
Initial performance test 24 1 24 0 0 0 0 $0
Technical $57.07
Repeat performance test c 24 0.2 4.8 0 0 0 0 $0
Clerical $30.88
Report review










New Plant










Notification of construction 2 1 2 0 0 0 0 $0


Notification of actual startup 0.5 1 0.5 0 0 0 0 $0


Notification of initial test 0.5 1.2 0.6 0 0 0 0 $0


Review test results 8 1.2 9.6 0 0 0 0 $0


Notification of demonstration of CMS 0.5 1 0.5 0 0 0 0 $0


Existing Plant










Quarterly report of VOCs emission exceedances d 2 0.5 1 22 22 1.1 2.2 $1,408.08


Semiannual report of no VOC emission exceedances e 2 2 4 22 88 4.4 8.8 $5,632.31


Notification of limit exceedance for extruded fiber 2 1 2 0 0 0 0 $0


TOTAL ANNUAL BURDEN AND COST (rounded) f



127 $7,040














Assumptions:










a We have assumed that the average number of respondents that will be subject to the rule will be 22. There will be no additional new source that will become subject to the rule over the three-year period of this ICR.


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 We have assumed that 20 percent of initial performance tests will be repeated.


d We have assumed that each respondent will submit one quarterly report every other year due to excess of volatile organic compounds (VOCs) emissions.


e Semiannual reports are required of all respondents.


f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.



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 Respondent1 Number of New Respondents Total Capital/Startup Cost, (B X C) Annual O&M Costs for One Respondent1 Number of Respondents with O&M Total O&M,
(E x F)




Flow indicator for solvent feed $5,045 0 $0 $11,466 22 $252,258

CEPCI 2009: 521.9
Totals (rounded)2

$0

$252,000 $252,000
CEPCI 2023: 797.9
1 Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.









2 Costs have been adjusted to 2023 dollars using the CEPCI Index.










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 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)
1 0 22 0 0 22
2 0 22 0 0 22
3 0 22 0 0 22
Average 0 22 0 0 22
1 New respondents include sources with constructed, reconstructed and modified affected facilities.

Sheet 6: 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 construction/‌reconstruction 0 1 0 0
Notification of actual startup 0 1 0 0
Notification of initial performance test 0 1 0 0
Report of performance tests 0 1 0 0
Report of repeat of performance test 0 0.2 0 0
Quarterly report of VOCs emission exceedances 22 0.5 0 11
Semiannual report of no excess emissions 22 2 0 44
Notification of extruded fiber limit exceedance 22 0 0 0


Total (rounded) 55
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