Burden Tables

Status: Original and derived artifacts are available for this document.

Download: xlsx | pdf | html

114.66

Annual Respondent Burden and Cost (40 CFR Part 63 Subpart HHHHHHH)
(A)Respondent
Hours per
Occurrence
(Technical Hours)

51.95 Labor rates based on May 2025 data from the Bureuf of Labor Statistics for NAICS 325000

174.03

(B)
Number of
Occurrences per
Respondent per
Year

(C)
Hours per
Respondent per
Year
(C = A x B)

(D)
Number of
Respondents per
Year a

(E)
Technical Hours
per Year
(E = C x D)

(F)
Management
Hours per Year
(F = E x 0.05)

16

1

16

0

0

0

0

$0

a) Stripped Wastewater: TOHAP e

-10

12

-117

0

0

0

0

$0

b) Uncontrolled Wastewater: TOHAP e

-24

1

-24

0

0

0

0

$0

Burden Item

1. Applications

not applicable

2. Surveys and Studies

not applicable

(G)Clerical Hours
(H)
per Year(G = E x Total Labor Costs
0.1)
per Year b

3. Reporting Requirements
A. Familiarization with Regulatory Requirements c,d
B. Required Activities
1) Periodic Performance Test, Sampling, and Report

C. Create Information

Incl. in 3.B

D. Gather Information

Incl. in 3.E

E. Report Preparation

not applicable g

Subtotal for Reporting Requirements

0

$0

4. Recordkeeping Requirements
A. Familiarization with Regulatory Requirements

Incl. in 3.A

B. Implement Activities

not applicable

C. Develop Record System

not applicable

D. Record Information
1) Records of TOHAP Wastewater Requirements
E. Personnel Training
F. Time for Audits
TOTAL LABOR BURDEN AND COSTS (rounded)
GRAND TOTAL (rounded) f

1

-15

0

0

0

0

$0

not applicable

Subtotal for Recordkeeping Requirements
TOTAL CAPITAL AND O&M COST (rounded)

-15
Incl. in 3.B

f

f

0

$0

0

$0
$0
$0

2026:

58.62

79.01

31.73

(E)
(F)
Technical PersonManagement
Hours per Year Person-Hours per
(E = C x D)
Year
(F = E x 0.05)

(G)
Clerical PersonHours per Year
(G = E x 0.1)

Annual EPA Burden and Cost (40 CFR Part 63 Subpart HHHHHHH)
(A)
(B)
(C)
EPA Person-Hours
Number of
EPA Person-Hours
per Occurrence Occurrences per per Plant per Year
Plant per Year
(C = A x B)

Burden Item

1. Applications

(D)
Plants per Year

not applicable

2. Familiarization with Rule Requirements

2

1

2

10

20

1

2

A. Observe initial performance tests

48

1

48

0

0

0

0

B. Excess emissions -- Enforcement Activities

24

1

24

0

0

0

0

1

32

0

0

0

0

a

3. Required Activities

C. Create Information

not applicable

D. Gather Information

not applicable
not applicable c

E. Report Reviews
F. Prepare annual summary report

32

d

4. Travel expenses: (1 person * 30 hours per year / 8 hours per day * $75 per diem) + ($600 per round trip) =
TOTAL ANNUAL BURDEN AND COST (rounded)

e

n/a

per trip
23

ATTACHMENT E: RECORDKEEPING AND REPORTING COST ALGORITHM
February 9, 2012

Record Keeping and Reporting Burden by Emission Point
Note: This table is used to caluclate the record keeping and reporting burden by emission point for the PVC NESHAP. The costs presented
in the table below represent costs not otherwise included in the PVC NESHAP Impact estimate (i.e., testing and monitoring costs are already
included in the PVC NESHAP impacts estimate, therefore, they are not included in the table below). The costs presented in the table below
should be added to the previously calculated PVC Impacts to obtain an impacts estimate which includes record keeping and reporting.

Record Keeping and Reporting Burden By Emission Point
Annual Cost ($/yr)
Initial Cost
Initial Notes
Annual Notes
($)
Yr 1
Yr 2
Yr 3
Resins
#REF! a,b,d
#REF!
#REF!
#NAME? e,f,g
Process Vents
#REF! a,b,c,d
#REF!
#REF!
#NAME? e,f,g
Wastewater
#REF! a,b,d
#REF!
#REF!
#NAME? e,f,g
Equipment Leaks
#REF! a,b,d
#REF!
#REF!
#NAME? e,f,g,h
Storage Vessels
#REF! a,d
#REF!
#REF!
#NAME? e,f,g
Heat Exchange Systems
#REF! a,b,d
#REF!
#REF!
#NAME? e,f,g
Other Sources
#REF! a,d
#REF!
#REF!
#NAME? e,f,g
Total
#REF!
#REF!
#REF!
#NAME?
a Labor/Non Labor Costs to "Read/Understand Rule Requirements" divided by 7 emission points
b Initial Performance Test/Sampling/Report
c Establishment of operating parameters and monitoring plan
d Report preparation for item 3.E.1-6 divided by 7 emission points
e Periodic sampling/testing/and monitoring (not applicable for process vents in year 1)
f Years 2 and 3 include items 3.E.5 and 3.E.6 divided by 7 emission points
g In year 2 and 3, recordkeeping items under 4.D are included
h includes annual labor cost for PRD monitoring system
Emission Point

Equipment Leaks BTF Costs Calculation on a Facility Basis
Equipment Leaks
#REF!
Equipment Leaks
#REF!
Equipment Leaks
#REF!

#REF!
#REF!
#REF!

#REF!
#REF!
#REF!

#NAME? Facilities going from V to UU
#NAME? MACT
#NAME? Incremental BTF Costs for Facilities going from V to UU

2. Required activities
a. Perf. spec. tests (certif.) for CMS

11

1

11

Notes:
2. Person-hours per occurrence for CMS performance specification costs are based on the performance specification costs to certify CMS ($700) divided by the composite hourly
labor rate ($66.41/hr).
Sources:
1. Bureau of Labor Statistics, Occupational Employment Statistics, May 2008 National Industry-Specific Occupational Employment and Wage Estimates.
2. Hospital/Medical/Infectious Waste Incinerators (HMIWI) [EPA-HQ-OAR2006-0534] Testing and Monitoring Options and Costs Memo (IV-B-66).

Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A)
Capital/Startup
Cost for One
Respondent

(B)
Number of New
Respondents

(C)
(D)
Total
Annual O&M Costs
Capital/Startup/O&M Item
Capital/Startup
for One
Cost
Respondent
(C = A x B)
$820
0
$0
-$9,840
Stripped Wastewater: TOHAP Testing 1
2
$2,091
0
$0
-$2,091
Uncontrolled Wastewater: TOHAP Testing
Total
$0
Note: Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
O&M costs shown as negative to reflect savings from no longer performing TOHAP wastewater testing.
1
Average cost for TOHAP testing is approximately $820 per major source, and 1 test per major source per month.
2
TOHAP testing on uncontrolled streams is performed annually. There are an average of 3 uncontrolled streams per facility.

(E)
Number of
Respondents with
O&M
0
0

(F)
Total O&M
(F = D x E)
$0
$0
$0