Burden Calculation Tables

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Overview

Summary
Table 1
Table 2
Capital O&M
Responses
Respondents

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Sheet 1: Summary

ICR Summary Information
Hours per Response	29
Number of Respondents	3
Total Estimated Burden Hours	176
Total Estimated Costs	$21,100
Annualized Capital O&M	$45
Total Annual Responses	6
Form Number	Not Applicable

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Sheet 2: Table 1

Table 1: Annual Respondent Burden and Cost – NESHAP for Chemical Preparations Industry (40 CFR Part 63, Subpart BBBBBBB) (Renewal)
Burden Items	(A) Respondent Hours per Occurrence	(B) Number of Occurrences per Respondent per Year	(C) Hours per Respondent per Year (A x B)	(D) Number of Respondents per Year a	(E) Technical Hours per Year (C x D)	(F) Management Hours per Year (E x 0.05)a	(G) Clerical Hours per Year (Ex0.1)a	(H) Total Labor Costs per Year, $b
1. Familiarization with the regulatory requirements	4	1	4	3	12	0.6	1.2	$1,656.87
2. Required activities
a. Initial performance tests c, d	8	1	8	0	0	0	0	$0
b. Engineering calculations or performance guarantees d, e	8	1	8	0	0	0	0	$0		Labor Rates
c. Continuous parameter monitoring e, f	8	1	8	0	0	0	0	$0		Management	$157.61
3. Reporting requirements										Technical	$123.94
a. Initial notification that existing facilities are subject to the standard c, g	4	1	4	0	0	0	0	$0		Clerical	$62.52
b. Notification of new area sources c
(1)     Notification of intent to construct/reconstruct	4	1	4	0	0	0	0	$0
(2)     Notification to commence construct/reconstruct	4	1	4	0	0	0	0	$0
(3)     Notification of startup	4	1	4	0	0	0	0	$0
c. Request for compliance extension h	4	1	4	0	0	0	0	$0
d. Notification of initial performance test c, d	2	1	2	0	0	0	0	$0
e. Notification of compliance status c	4	1	4	0	0	0	0	$0
f. Gather information for semiannual reports i	4	2	8	3	24	1.2	2.4	$3,313.74
g. Semiannual compliance reports i	4	2	8	3	24	1.2	2.4	$3,313.74
Subtotal for Reporting Requirements					69			$8,284.35
4. Recordkeeping Requirements
a. Develop a record system c	4	1	4	0	0	0	0	$0
b. Develop a monitoring plan c	4	1	4	0	0	0	0	$0
c. Implement activities								$0
(1)     Record performance tests c	1	1	1	0	0	0	0	$0
(2)     Record periods of target HAP service and deviations	0.5	52	3	3	9	0.45	0.9	$1,242.65
(3)     Continuous parameter monitoring system inspections, calibration and maintenance j	1	12	12	3	36	1.8	3.6	$4,970.61
(4)     Vent collection systems and control inspections	1	12	12	3	36	1.8	3.6	$4,970.61
d. Store, file and maintain records	4	1	4	3	12	0.6	1.2	$1,656.87
5. Time to train personnel	4	1	4	0	0	0	0	$0
6. Prepare for and participate in audits	0	0	0	0	0	0	0	$0
Subtotal for Recordkeeping Requirements					107			$12,840.74
TOTAL Labor Burden and Costs (rounded) k					176			$21,100
TOTAL Capital and O&M Costs (rounded) k								$45		29	hr/resp
GRAND TOTAL (rounded) k								$21,100
Assumptions:
a. We have assumed that there are approximately 3 respondents subject to the rule, with no new sources expected over the three-year period covered by this ICR.
b. This ICR uses the following labor rates: Managerial $157.61 ($75.05 + 110%); Technical $123.94 ($59.02 + 110%); and Clerical $62.52 ($29.77 + 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2021, “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 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 assume that this is a one-time only activity for new facilities.
d. One-time activity for new and existing facilities after promulgation of final rule. We assume that performance tests are not required for any of the existing facilities to demonstrate compliance with the emission limits. Instead we assume that 50 percent of the industry will have existing performance tests that demonstrate compliance with the emission limits, and the other 50 percent will use performance guarantees or engineering calculations to demonstrate compliance.
e. We assume that all existing facilities will use their existing continuous parameter monitoring equipment or alarms to demonstrate continuous compliance.
f. There is no additional burden for new monitoring equipment because additional add-on control devices are not expected to be needed to demonstrate compliance with the emission limits and facilities are already equipped with equipment to monitor existing control device parameters.
g. Existing facilities must submit notification that they are subject to the standard within 120 days of the effective date of final rule (December 30, 2009).
h We assume that compliance extensions will not be necessary.
i We assume that all respondents will have deviations requiring submittal of compliance reports semi-annually. We assume that semiannual compliance reports will take each respondent 4 hours twice per year to prepare.
j We have assumed that each respondent will take 1 hour 12 times per year to implement the continuous parameter monitoring system inspections, calibration and maintenance activity.
k Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: Table 2

Table 2: Average Annual EPA Burden and Cost – NESHAP for Chemical Preparations Industry (40 CFR Part 63, Subpart BBBBBBB) (Renewal)
Burden Items	(A) EPA Hours per Occurrence	(B) Occurrences per Plant per Year	(C) EPA Hours per Plant per Year (AxB)	(D) Plants per Year a	(E) Technical EPA Hours per Year (CxD)	(F) Managerial Hours per Year (Ex0.05)	(G) Clerical Hours per Year (Ex0.1)	(H) Cost per year, $b
1. Familiarization with the regulatory requirements	2	1	2	0	0	0	0	$0
2. Required activities
a. Initial performance tests c, d, e	8	1	8	0	0	0	0	$0
b. Review initial performance test reports, performance guarantees, engineering	4	1	4	0	0	0	0	$0
c. Enter and update information into agency recordkeeping system	1	1	1	0	0	0	0	$0		Labor Rates
3. Excess emissions – enforcement activities f	N/A									Technical	$70.56
4. Notification requirements										Management	$52.37
a. Review initial notification that existing facilities are subject to the standard c, g	1	1	1	0	0	0	0	$0		Clerical	$28.34
b. Notifications for new area sources h
(1)     Review notification of intent to construct/reconstruct	4	1	4	0	0	0	0	$0
(2)     Review notification of commencement of construction/reconstruction	2	1	2	0	0	0	0	$0
(3) Review notification of startup	2	1	2	0	0	0	0	$0
c. Review request for compliance extension i	2	1	2	0	0	0	0	$0
d. Review notification of initial performance tests c, d, e	1	1	1	0	0	0	0	$0
e. Review notification of compliance status c, j	4	1	4	0	0	0	0	$0
5. Reporting requirements – review semiannual compliance reports k	4	2	8	0.8	6	0.3	0.6	$456.08
TOTAL (rounded) l					7			$456
Assumptions:
a. We have assumed that there are approximately 3 respondents subject to the rule, with no new sources expected over the three-year period covered by this ICR.
b. This cost is based on the average hourly labor rate as follows: Managerial $70.56 (GS-13, Step 5, $44.10 + 60%); Technical $52.37 (GS-12, Step 1, $32.73 + 60%); and Clerical $28.34 (GS-6, Step 3, $17.17 + 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), 2022 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 assume that this is a one-time only cost.
d. We assume that EPA technical personnel will observe all performance tests conducted by new sources.
e. We have assumed that not emission tests will need to be performed. Facilities will utilize existing performance tests, performance guarantees, or engineering calculations to demonstrate initial compliance
f. We have assumed that there would be no enforcement activities for the 3-year period covered by this ICR.
g. We assume that existing area source facilities must submit notification that they are subject to and the standard within 120 days of the effective date of the final rule (December 30, 2009).
h There are no new sources expected over the next three years of this ICR.
i We have assumed that compliance extensions will not be necessary.
j Assume that EPA technical personnel will review all of the initial compliance status notifications for new sources.
k We assume that EPA technical personnel will review 25 percent of the semiannual compliance reports.
l Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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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 Respondent	Number of New Respondents a	Total Capital/Startup Cost, (B X C)	Annual O&M Costs for One Respondent	Number of Respondents with O&M b	Total O&M, (E X F)
Continuous parameter monitoring equipment1	NA	NA	NA	NA	NA	NA
Photocopy and postage2	NA	NA	NA	$15	3	$45
Totals (rounded)			$0			$45
Note: Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
1 Assumes all affected sources will use existing continuous parameter monitoring equipment or alarms to demonstrate continuous compliance. Therefore, no new equipment would be required to comply with the recordkeeping and reporting requirements of the NESHAP and no capital costs would be incurred. We assume the O&M costs associated with this equipment is negligible.
2 The annual operation and maintenance (O&M) costs include the cost of photocopying and mailing reports for initial compliance demonstrations (engineering calculations or performance guarantee information) and semiannual compliance reports. Photocopying and postage costs are incurred when reports required by the NESHAP are submitted to regulatory agencies. These costs were estimated to be $7.50 per report.								$45

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Sheet 5: 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
Semiannual reporta	3	2	0	6
			Total	6
a Although the rule allows for annual reports when there are no deviations, we assume that all respondents will have deviations requiring submittal of compliance reports semi-annually.

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Sheet 6: 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 a	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	3	0	0	3
2	0	3	0	0	3
3	0	3	0	0	3
Average	0	3	0	0	3
a New respondents include sources with constructed, reconstructed and modified affected facilities.