Cost and Burden Calculation Tables

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ICR Summary Information
Hours per Response
203
Number of Respondents
19
Total Estimated Burden Hours
23,300
Total Estimated Costs
$6,240,000
Annualized Capital O&M
$3,050,000
Total Annual Responses
115
Form Number
Not Applicable

Table 1: Annual Respondent Burden and Cost – NESHAP for the Manufacture of Amino/Phenolic Resins (40

(A)

Burden Item

1. Applications
2. Survey and Studies
3. Reporting Requirements
A. Familiarize with regulatory requirements c, d
B. Plan activities
C. Training
D. Create, test and research development e, f
E. Gather, monitor and inspect information
F. Process, compile and review
G. Write Report
1) Pre-compliance report
2) Notification of compliance status
3) Semiannual summary report g
4) Activities for periodic report related to storage vessel
maintenance h
5) Reports of malfunctions
6) Other reports
7) Leak detection and repair (LDAR) reporting
Subtotal for Reporting Requirements
4. Recordkeeping Requirements
A. Familiarize with regulatory requirements c, d
B. Plan activities
C. Implement activities
1) Malfunction records
2a) Monitoring records
2b) Continuous process vent records h
3) Batch process vent records
4) Aggregate batch vent stream records
5) Leak detection and repair (LDAR) records
6) Other records and documentation
D. Develop record system
1) Record/disclose information
2) Store, file, maintain information i
E. Time to enter information
1) Malfunction records
2) Monitoring records
3a) Storage vessel - maintenance & recording info h
3b) Continuous process vent records h
4) Batch process vent records
5) Aggregate batch vent stream records

(B)
No. of
Technical
occurrences
person-hours
per
per occurrence respondent
per year

(C)
Technical
person-hours
per
respondent
per year
(C=AxB)

(D)
Respondents
per year a

N/A
N/A
16
8
16
320
208
48

1
1
1
1
1
2

16
8
16
320
208
96

19
19
19
1
19
19

20
20
40

1
1
2

20
20
80

0
0
19

1

1

1

15

20
8
60

2
2
1

40
16
60

19
19
19

6
24
4
24
24
24
24

2
2
2
2
2
2
2

12
48
8
48
48
48
48

19
19
1
19
19
19
19

16
4

2
2

32
8

19
19

4
4
1
4
4
4

2
2
1
2
2
2

8
8
1
8
8
8

19
19
15
1
19
19

See 3A
See 3B

6) Leak detection and repair (LDAR) records
7) Other records and documentation
F. Time to train personnel
1) Control equipment inspect and monitor
2) Leak detection and repair
G. Time for audits
Subtotal for Recordkeeping Requirements
Total Labor Burden and Costs (rounded) j
Total Capital and O&M Cost (rounded) j
Grand Total (rounded) j

4
8

2
2

8
16

19
19

40
40
N/A

2
2

80
80

19
19

Assumptions:
a
This ICR assumes there are 19 respondents subject to the rule and that no additional respondents will become subject over the next three ye

This ICR uses the following labor rates: Managerial $172.41 ($82.10+ 110%); Technical $141.75 ($67.50 + 110%); and Clerical $71.36 ($
Department of Labor, Bureau of Labor Statistics, December 2023, “Table 2. Civilian workers by occupational and industry group.” The rates
are increased by 110 percent to account for varying industry wage rates and the additional overhead business costs of employing workers bey
expenses associated with hiring, training, and equipping their employees. This ICR assumes that Managerial hours are 5 percent of Technica
hours.
b

c

This ICR assumes that all respondents will have to familiarize with the regulatory requirements each year.

d

We assume that it will take 16 hours for each respondent to familiarize with regulatory requirements.

Initial performance testing was assumed to take 280 technical hours (1 test leader for two weeks and 5 feet crew for one week), with an add
monitoring levels for a total of 320 respondent hours per occurrence.
e

f

We assume that 5 percent of the initial tests will be repeated during each successive year.

g

We assume that it will take each respondent 40 hours two times per year to complete reports (semiannual reporting).

Includes burden from activities based on amendments in the October 15, 2018 final rule (83 FR 51842). These activities only apply to own
these provisions (15 facilities), or continuous process vents (1 facility).
h

i

We assume that it will take 4 hours two times per year to gather monitoring information and maintain monitoring equipment.

j

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

/Phenolic Resins (40 CFR Part 63, Subpart OOO) (Renewal)

(E)

(F)

(G)

Technical
Management
Clerical hours
hours per year hours per year
per year
(E=CxD)
(F=Ex0.05)

(H)
Total cost per
year ($) b

(G=Ex0.10)

304
152
304
320
3,952
1,824

15
8
15
16
198
91

30
15
30
32
395
182

$47,881.98
$23,940.99
$47,881.98
$50,402.08
$622,465.69
$287,291.86

0
0
1,520

0
0
76

0
0
152

$0
$0
$239,409.88

15

1

2

$2,362.60

760
304
1,140

38
15
57
12,184

76
30
114

$119,704.94
$47,881.98
$179,557.41
$1,668,781

228
912
8
912
912
912
912

11
46
0.4
46
46
46
46

23
91
1
91
91
91
91

$35,911.48
$143,645.93
$1,260.05
$143,645.93
$143,645.93
$143,645.93
$143,645.93

608
152

30
8

61
15

$95,763.95
$23,940.99

152
152
15
8
152
152

8
8
1
0.4
8
8

15
15
2
1
15
15

$23,940.99
$23,940.99
$2,362.60
$1,260.05
$23,940.99
$23,940.99

Labor Rates
Management
$172.41
Technical
$141.75
Clerical
$71.36

152
304

8
15

15
30

$23,940.99
$47,881.98

1,520
1,520

76
76

152
152

$239,409.88
$239,409.88

11,135
23,300

$1,525,135
$3,190,000
$3,050,000
$6,240,000

bject over the next three years.

%); and Clerical $71.36 ($33.98 + 110%). These rates are from the United States
d industry group.” The rates are from column 1, “Total compensation.” The rates
s of employing workers beyond their wages and benefits, including business
s are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical

for one week), with an additional 40 hours for the establishment of parameter

ing).

ctivities only apply to owners and operators of storage vessels that are subject to

g equipment.

203 hrs/response

Table 2: Average Annual EPA Burden and Cost – NESHAP for the Manufacture of Amino/Phenolic Resins (4
OOO) (Renewal)
(A)

Burden Item

Initial performance test
Repeat performance test c
Report review
a) Notification of construction/reconstruction
b) Notification of anticipated startup
c) Notification of actual startup
d) Notification of modification
e) Notification of compliance status
f) Notification of performance test/review test
report d
g) Notification of process change
h) Notification of inspection of storage vessel
i) Notification of change in primary product
j) Pre-compliance report
k) Storage vessel initial compliance demonstration
l) Periodic reports of compliance status e
m) Semiannual summary report
n) Reports of malfunctions
TOTAL (rounded) f

(B)
(C)
(D)
Number of EPA Hours
Per
EPA Hours Occurrences
Number of
Per
Respondent Respondents
per
Occurrence Respondent Per Year
Per Year a
Per Year
(C=AxB)
N/A
20
1
20
1
N/A
N/A
N/A
N/A
N/A
4

1

4

1

N/A
N/A
N/A
N/A
N/A
4
2
2

2
2
2

8
4
4

19
19
19

Assumptions:
a
This ICR assumes there are 19 respondents subject to the rule and that no additional respondents will become subject over the next three ye

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
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
hours. These rates are from the Office of Personnel Management (OPM), 2024 General Schedule, which excludes locality, rates of pay. The
percent to account for the benefit packages available to government employees.
b

c

We assume that it would take 20 hours once per year for the Agency to view the repeat performance test.

d

We assume that it will take 4 hours once per year for the Agency to review the notification of performance test and the performance test re
We assume that it will take 4 hours twice per year for Agency to review the periodic report of compliance status.

e
f

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

re of Amino/Phenolic Resins (40 CFR Part 63, Subpart

(E)

(F)

(G)

(H)

Technical Management Clerical
Hours Per Hours Per Hours Per Total Costs, $
b
Year
Year
Year
(E=CXD) (F=Ex0.05) (G=Ex0.1)
20

1

2

$1,280.11
Labor Rates
$76.91
Management
$57.07
Technical
$30.88
Clerical

4

0.2

0.4

$256.02

152
76
76

7.6
3.8
3.8
377

15.2
7.6
7.6

$9,728.85
$4,864.43
$4,864.43
$21,000

ll become subject over the next three years

48.07 + 60%); Technical $57.07 (GS-12, Step 1, $35.67 + 60%); and
of Technical hours, and Clerical hours are 10 percent of Technical
ich excludes locality, rates of pay. The rates have been increased by 60

e test.

rmance test and the performance test report.
pliance status.

Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A)
Continuous Monitoring Device
pH Monitor

(B)
Capital/Startup
Cost for One
Respondent c

(C)
Number of
New
Respondents

$1,382

0

(D)
Total Capital/Startup
Cost, (B X C)
$0

Liquid Flow Monitor
$691
0
$0
O&M
$0
0
$0
a
Continuous process vent control systems
$3,330,054
0
$0
Monitoring equipment
$30,293
0
$0
b
Total
$0
a
We assume that there are 19 facilities in the Amino/Phenolic Resins category, however only 6 facilities are expected to operate emissions c
process vents. Further, 4 out of 6 back-end process vents are able to comply with the standard without any additional controls. The EPA curr
back-end CPVs located at 1 facility installed an RTO. Capital/Startup and Annual O&M Costs are average facility costs based on revised con
information from industry provided to the EPA as part of the October 15, 2018 final rule. We assumed that facilities are in compliance with t
amendments by October 15, 2019, and therefore there are no capital costs under this ICR renewal. For front-end CPVs at existing affected so
these CPVs are able to meet the standard without any additional controls. See the memorandum “National Impacts Associated with Final Sta
Storage Tanks in the Amino and Phenolic Resins Production Source Category” in Docket Id. No. EPA-HQ-OAR-2012-0133-0105 for additi

b
c

Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
This ICR updates the capital and O&M costs from 2014 dollars (CEPCI CE Index 576.1) to 2024 dollars (CEPCI CE Index 796.2).

ance (O&M) Costs
(E)
(F)
Annual O&M Costs Number of
for One Respondent Respondents
c
with O&M
$415

19

$138
$2,080
$1,459,239
$4,313

19
19
2
19

(G)
Total O&M
(E X F)
$7,878

$2,626
$39,520
$2,918,479
$81,954
$3,050,000
cilities are expected to operate emissions controls for continuous
out any additional controls. The EPA currently anticipates that 2
average facility costs based on revised control technology vendor
med that facilities are in compliance with the 2018 final rule
For front-end CPVs at existing affected sources, it is expected that
ational Impacts Associated with Final Standards for CPVs and
PA-HQ-OAR-2012-0133-0105 for additional information.

dollars (CEPCI CE Index 796.2).

CEPCI 2014 CE
INDEX

576.1

CEPCI 2024 CE
796.2
INDEX
CEPCI Ratio 1.3820517

Total Annual Responses
(A)

(B)

(C)

(D)

(E)

Total Annual
Responses
E=(BxC)+D

0

Information Collection Activity

Number of
Respondents

Number of
Responses

Number of
Existing
Respondents
That Keep
Records But Do
Not Submit
Reports

Initial notification and performance tests

0

1

0

Repeat performance test

1

1

0

1

Malfunction reports

19

2

0

38

Semiannual compliance reports

19

2

0

38

Other reports

19

2

0

38

a

a

Total
We assume that 5 percent of the initial tests will be repeated during each successive year.

115

Number of Respondents
Respondents That Submit Reports

(A)

a

(B)

Respondents That
Do Not Submit
Any Reports

(C)

(D)

(E)

Number of
Number of
Existing
Existing
Number of
Number of
Respondents that Respondents
Existing
Respondents
keep records but That Are Also
Respondents
(E=A+B+C-D)
do not submit
New
reports
Respondents

Year

Number of New
Respondents a

1

0

19

0

0

19

2

0

19

0

0

19

3

0

19

0

0

19

Average

0

19

0

0

19

New respondents include sources with constructed, reconstructed and modified affected facilities.