Burden Calculation Tables

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Overview

Respondents
Responses
Industry
Agency

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Sheet 1: Respondents

Type of Facility	Tire Manufacturing (no cord/Tube)	Tire Manufacturing with Cord (Tube)	Requirements:	ASingleton: Assume the two tread/retread facilities apply the same compliance option breakdown as the tire manufacturing facilities. Tread
Existing Facilities	19	2		2
Purchase Alternative	8	N/A for cord	Monthly purchase records
Monthly average alternative, no control device	13	2
Monthly average alternative, control device	0	0	NA - no sources.
New Facilities	0
Industry Consult from Korbin Smith, OAQPS, October 2017:
We surveyed RMA members to see which compliance option in the MACT they are using and here is what we found:
	% of overall respondents so that we can apply to all facilities including the ones not in the trade group:
Option (a) Purchase Alternative – 8 RMA member facilities use this option	40%
Option (b) Monthly average alternative, without using add-on control devices – 12 RMA member facilities use this compliance option	60%
Option (c) Monthly average alternative, using an add-on control device – No RMA member facilities use this option	0%

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Sheet 2: 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
Initial Notifications	0	1	0	0
Performance test notification	0	1	0	0
Compliance status notification	0	1	0	0
Notification of alternative monitoring method	0	1	0	0
Notification of reassessment of predominant use	0	1	0	0
Start-up Shutdown and malfunction plan	0	1	0	0
Site-specific monitoring plan	0	1	0	0
Performance test reports	0	1	0	0
Semiannual compliance reports	15	2	0	30
Annual compliance reports	8	1	0	8
Startup/shutdown/malfunction reports	0	2	0	0
			Total	38

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Sheet 3: Industry

					149.35	112.98	54.81
Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C=A x B)	(D) Respondents per year a	(E) Technical person- hours per year (E=C x D)	(F) Management person hours per year (E x 0.05)	(G) Clerical person hours per year (E x 0.1)	(H) Total Cost per yearb	Basis
1. Applications	N/A
2. Survey and Studies	N/A
3. Reporting Requirements
A. Familiarization with rule requirementsa	4	1	4	23	92	4.6	9.2	$14,764.16	Previous (expired) ICR
B. Required Activities
i. Performance test	30	0.25	7.5	0	0	0	0	$0	ERG estimate based on hours estimate for performance test in 1957.08 ICR. The facility time is to prepare and observe test, test itself is typically contracted out.
C. Create Information	See item 4.F
D. Gather existing information	N/A
E. Write reports
i. Initial Notifications c	2	1	2	0	0	0	0	$0	Previous (expired) ICR
ii. Performance test notification d	2	1	2	0	0	0	0	$0	Previous (expired) ICR. Applies once every 5 years for facilities using control devices
iii. Compliance status notification c	2	1	2	0	0	0	0	$0	Previous (expired) ICR
iv. Notification of alternative monitoring methodd	2	1	2	0	0	0	0	$0	ERG engineering judgment of 2 hours; simliar LOE as other notification line items (control device only)
v. Notification of reassessment of predominant usee	2	1	2	0	0	0	0	$0	ERG engineering judgment of 2 hours; simliar LOE as other notification line items. Assume 0 source (cord production only)
vi. Start-up Shutdown and malfunction pland	20	1	20	0	0	0	0	$0	ERG engineering judgement, time to write plan will require more hours than a notification.
vii. Site-specific monitoring pland	20	1	20	0	0	0	0	$0	ERG engineering judgement, time to write plan will be similar to writing an SSM plan.
viii. Performance test reports d	10	1	10	0	0	0	0	$0	ERG engineering judgement; this is time to review reports once testing contractor submits them to the facility.
ix. Semiannual compliance reports f	8	2	16	15	240	12	24	$38,515.20	Previous (expired) ICR
x. Annual compliance reports g	8	1	8	8	64	3.2	6.4	$10,270.72	Previous (expired) ICR
xi. Startup/shutdown/malfunction reportsd	4	2	8	0	0	0	0	$0	ERG engineering judgement, more time then a notification, but less than a plan. Assumes most data collection for report is automated obtained.
Subtotal for Reporting Requirements					455			$63,550
4. Recordkeeping Requirements
A. Familiarization with rule requirements	See 3.A
B. Plan activities c	N/A - one-time upon becoming subject
C. Implement Activities	N/A - covered by reporting and recordkeeping
E. Develop record system c	N/A - one-time upon becoming subject
F. Time to enter information
i. Records of notificationsc	2	1	2	0	0	0	0	$0	ERG engineering judgement
ii. Records of performance testsd	0.5	0.25	0.125	0	0	0	0	$0	ERG engineering judgement
iii. Records related to startup, shutdown, and malfunctiond	2	12	24	0	0	0	0	$0	ERG engineering judgement
iv. Monthly Purchase records - purchase alternativeg	2	12	24	8	192	9.6	19.2	$30,812.16	Previous (expired) ICR
v. Compliance calculation and supporting data - monthly average option h	0.5	365	182.5	15	2,738	136.88	273.75	$439,314	Previous (expired) ICR
vi. Method 311 or alternative resultsi	0.5	12	6	23	138	6.9	13.8	$22,146.24	ERG engineering judgement, filing of report results, results likely to be sent electronically.
vii. Control equipment O&M log d	4	1	4	0	0	0	0	$0	ERG engineering judgement, mimimal time to file the record but slightly more hours than the automated data collection, since it may involve hand-entry of data logs from O&M staff
viii. CPMS calibration validation recordsd	1	1	1	0	0	0	0	$0	ERG engineering judgement, mimimal time to file the record.
ix. Operating parameters d	1	1	1	0	0	0	0	$0	ERG engineering judgement, filing of automatically collected operating parameters
G. Time to train personnel	N/A - one-time upon becoming subject
H. Store, file and maintain records j	4	12	48	23	1,104	55.2	110.4	$177,169.92	Previous (expired) ICR
I. Retrieve records/reports j	4	12	48	23	1,104	55.2	110.4	$177,169.92	Previous (expired) ICR		responses	38
Subtotal for Recordkeeping Requirements					6,067			$846,612
TOTAL LABOR BURDEN AND COST (rounded)k					6,520			$910,000			hr per resp	172
Total CAPITAL and O&M COST (rounded)k								$0
GRAND TOTAL (rounded)k					6,520			$910,000
Assumptions:
a Based on recent updates to the facility inventory, we estimate there are approximately 23 respondents, including: 19 tire production, 2 tire and cord production, and 2 tread or retread-only facilities. No additional new or reconstructed sources becoming subject to the rule over the next three years.
b This ICR uses the following labor rates: $149.35 per hour for Executive, Administrative, and Managerial labor; $112.98 per hour for Technical labor, and $54.81 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2017, “Table 2: Civilian Workers, by Occupational and Industry Group.” 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 One time only activity. The existing sources have already completed this requirement and there are no new sources, so no burden is estimated during this ICR renewal period.
d This activity is only required for units complying with control devices. Based on consultations with the industry, none of the facilities are using control devices. For performance tests, should they occur their frequency is once every five years.
e The EPA does not estimate anyone will submit these reassessment notifications.
f The facilities using the monthly average compliance option will have to submit semi-annual compliance reports. Based on consultations with industry, we estimate 60 percent of the tire production facilities and tread/re-tread facilities use this option. In addition, all of the tire cord facilities use this option.
g Facilities that are using the purchase option to comply will have to demonstrate monthly that only compliant coatings were used and are allowed to submit the reports annually instead of semi-annually.
h Facilities that are using the monthly compliance option will have to collect material usage data for the monthly average compliance calculation. We assumed daily data collection as a conservative estimate.
I Both facilities using the purchasing alternative or the monthly averaging alternative must keep records of the Method 311 (or alternative test method) results.
j All facilities will store and retrieve records/reports
k Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 4: Agency

					48.08	64.8	26.02
Activity	(A) EPA person-hours per occurrence	(B) No. of occurrences per plant per year	(C) EPA person hours per plant per year (A x B)	(D) Plants per yeara	(E) Technical person-hours per year (C x D)	(F) Management person-hours per year (E x 0.05)	(G) Clerical person-hours per year (E x 0.1)	(H) Cost, $b
Review Initial notification reports c	2	0	0	0	0	0	0	$0
Review Performance Test Notificationsd	2	0.25	0.5	0	0	0	0	$0
Review notifications of compliance statusc	2	1	2	0	0	0	0	$0
Review notifications of alternative monitoringd	2	2	4	0	0	0	0	$0
Review notifications of reassessment of predominant used	2	3	6	0	0	0	0	$0
Review performance test resultsd	10	0.25	2.5	0	0	0	0	$0
Review semiannual summary reportsa	4	2	8	15	120	6	12	$6,470.64
Review annual summary reportsa	4	1	4	8	32	1.6	3.2	$1,725.50
Review start-up, shutdown malfunction reportsd	4	1	4	0	0	0	0	$0
TOTAL ANNUAL BURDEN AND COST (rounded)e					175			$8,200
Assumptions:
a Based on recent updates to the facility inventory, we estimate there are approximately 23 respondents, including: 19 tire production, 2 tire and cord production, and 2 tread or retread-only facilities. No additional new or reconstructed sources becoming subject to the rule over the next three years. Facilities that are using the purchase option to comply will have to demonstrate monthly that only compliant coatings were used and are allowed to submit the reports annually instead of semi-annually. Facilities that are using the monthly compliance option will have to collect material usage data for the monthly average compliance calculation. We assumed daily data collection as a conservative estimate.
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, $48.08 for Technical, and $26.02 Clerical. These rates are from the Office of Personnel Management (OPM) “2017 General Schedule” which excludes locality rates of pay.
c These are initial requirements that apply to new sources only
d Since no facilities are using control devices to comply with the rule, the performance test, alternative monitoring and start-up, shutdown and malfunction reports are not being submitted by industry and therefore do not need to be reviewed. In addition, we have assumed that no facilities are submitting notifications of reassessment of predominant use.
e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.