Burden Tables

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Overview

Table 1
Table 2

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Sheet 1: Table 1

Table 2: Average Annual EPA Burden and Cost – NESHAP for Cellulose Products Manufacturing (40 CFR Part 63, Subpart UUUU) (Renewal)
					108.28	144.33	53.34
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 (C=AxB)	Respondents per year a	Technical person- hours per year (E=CxD)	Management person hours per year (F=Ex0.05)	Clerical person hours per year (G=Ex0.1)	Total Cost per year b
1. Applications	N/A
2. Survey and Studies	N/A
3. Reporting requirements
A. Familiarize with regulatory requirements c	8	1	8	13	104	5.2	10.4	$12,566.37
B. Required activities	N/A
C. Create information	See 3E
D. Gather existing information	See 3E
E. Write Report
Semiannual report on no deviations d	8	2	16	10	160	8	16	$19,332.88
Semiannual report on deviations e	16	2	32	3	96	4.8	9.6	$11,599.73
Semiannual report of startup, shutdown, malfunction (SSM) f	8	2	16	13	208	10.4	20.8	$25,132.74
Semiannual report on equipment leaks g	303	2	606	4	2,424	121.2	242.4	$292,893.13
Semiannual report on wastewater	See 4E
Semiannual report on all other reports h	8	2	16	13	208	10.4	20.8	$25,132.74
Subtotal for Reporting Requirements					3,680			$386,658
4. Recordkeeping requirements
A. Familiarize with regulatory requirements	See 3A
B. Plan activities	N/A
C. Implement Activities	N/A
D. Develop record system	N/A
E. Time to enter information
Records of SSM i	1.5	52	78	13	1,014	50.7	101.4	$122,522.13
Records of continuous parameters monitoring system (CPMS) data
Record continuous monitor parameters j	1	365	365	13	4,745	237.25	474.5	$573,340.72
Compile data k	24	2	48	13	624	31.2	62.4	$75,398.23
Enter and verify information for semiannual report k	16	2	32	13	416	20.8	41.6	$50,265.49
Records of closed-loop systems l	2	2	4	1	4	0.2	0.4	$483.32
Records of nitrogen systems m	2	2	4	9	36	1.8	3.6	$4,349.90
Records of material balances n	8	2	16	9	144	7.2	14.4	$17,399.59
Records of supporting calculations o	8	2	16	13	208	10.4	20.8	$25,132.74
Records for extended cookout p	8	2	16	1	16	0.8	1.6	$1,933.29
Records for equipment leaks	See 3E
All other records	See 3E
F. Time for refresher training of personnel q	16	1	16	13	208	10.4	20.8	$25,132.74
G. Time for audits	N/A
Subtotal for Recordkeeping Requirements					8,527			$895,958		responses	hr/response
TOTAL LABOR BURDEN AND COST (rounded) r					12,200			$1,280,000		94	129.787234042553
TOTAL CAPITAL AND O&M COST (rounded) r								$1,010
GRAND TOTAL (rounded) r								$1,280,000
Assumptions:
a We have assumed that there are approximately 13 sources subject to the standard which includes the following facilities: 4 cellulose ether; 4 cellulosic sponge; 3 cellulose food casing; 1 rayon; and 1 cellophane. There will be no additional new sources per year that will become subject to the rule over the three-year period of this ICR.
b This ICR uses the following labor rates: $144.33 per hour for Executive, Administrative, and Managerial labor; $108.28 per hour for Technical labor, and $53.34 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2016, Table 2. Civilian Workers, by Occupational and Industry groups. 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 all existing respondents will have to familiarize with the regulatory requirements each year.
d We have assumed that 80 percent of respondents will report no deviation.
e We have assumed that 20 percent of respondents will report a deviation.
f We have assumed that all of the existing sources will be required to submit an SSM report.
g We have assumed that it will take each respondent 303 hours on a semiannual basis to write reports for 4 cellulose ether facilities subject to leak detection and repair (LDAR) requirements.
h All other reports, including changes of information, closed-vent systems, bypass lines, heat exchanger systems, and storage vessel control device maintenance, will be reported twice per year.
i We have assumed that SSM records will be recorded on a weekly basis.
j We have assumed that it will take each respondent one hour to record information on a daily basis on process vent, storage tank and wastewater monitoring and inspections.
k We have assumed that each respondent will enter and verify information for the semiannual report twice per year.
l We have assumed that it will take respondent two hours to enter information on 1 cellulose ether facility with a closed-loop system.
m We have assumed that it will take each of the 9 respondents two hours to enter information on 9 viscose process facilities with CS2, unloading and storage operations.
n We have assumed that it will take each of the 9 respondents eight hours to enter information on 9 viscose process facilities using material balances.
o We have assumed that it will take eight hours for each respondent to enter information on supporting calculations twice per year.
p We have assumed that it will take respondents eight hours to enter information on 1 cellulose ether facility that uses extended cookout.
q We have assumed that it will take each of the thirteen respondent two days (16 hours) to provide refresher training to personnel.
r 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 – NESHAP for Cellulose Products Manufacturing (40 CFR Part 63, Subpart UUUU) (Renewal)
					48.08	64.8	26.02
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 (C=AxB)	Plants per year a	Technical person-hours per year (E=CxD)	Management person-hours per year (F=Ex0.05)	Clerical person-hours per year (G=Ex0.1)	Cost, $ b
Activity
Initial performance test	N/A
Repeat performance test	N/A
Excess emissions enforcement activities	120	1	120	0	0	0	0	$0
Review reports
Review semiannual compliance report
Report of no deviations c	2	2	4	10	40	2	4	$2,156.88
Report of deviations d	8	2	16	3	48	2.4	4.8	$2,588.26
Report of SSM e	2	2	4	13	52	2.6	5.2	$2,803.94
Reports of equipment leaks f	8	2	16	4	64	3.2	6.4	$3,451.01
Report on wastewater g	8	2	16	4	64	3.2	6.4	$3,451.01
Report on all other reports h	2	2	4	13	52	2.6	5.2	$2,803.94
TOTAL ANNUAL BURDEN AND COST (rounded)					368			$17,300
Assumptions:
a We have assumed that there are approximately 13 sources that are subject to the standard which includes the following facilities: 4 cellulose ether; 4 cellulosic sponge; 3 cellulose food casing; 1 rayon; and 1 cellophane.
b This cost is based on the following hourly labor rates times a 1.6 benefits multiplication factor to account for government overhead expenses: $64.80 for Managerial (GS-13, Step 5, $40.50 x 1.6), $48.08 for Technical (GS-12, Step 1, $30.05 x 1.6) and $26.02 Clerical (GS-6, Step 3, $16.26 x 1.6). These rates are from the Office of Personnel Management (OPM) 2017 General Schedule which excludes locality rates of pay.
c We have assumed that 80 percent of respondents will report no deviation.
d We have assumed that 20 percent of respondents will report deviation.
e We have assumed that all of the existing respondents will be required to submit an SSM report.
f We have assumed that each of the 4 respondents for cellulose ether facilities will review their report on equipment leaks two times per year.
g We have assumed that it will take each respondent eight hours to review reports of 4 cellulose ether facilities subject to LDAR and wastewater requirements.
h We have assumed that all other reports, including changes of information, closed-vent systems, bypass lines, heat exchanger systems, and storage vessel control device maintenance, will be reported twice a year.