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	143
Number of Respondents	8
Total Estimated Burden Hours	7,256
Total Estimated Costs	$1,078,427
Annualized Capital O&M	$163,533
Total Annual Responses	51
Form Number	5900-647

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Sheet 2: Table 1

Table 1: Average Annual Respondent Burden and Cost – NESHAP for Cellulose Products Manufacturing (40 CFR Part 63, Subpart UUUU) (Renewal)
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										Labor Rates
2. Survey and Studies	N/A										Management	$163.17
3. Reporting Requirements											Technical	$130.28
A. Familiarize with regulatory requirements c	8	1	8	2.7	21	1.1	2.1	$3,094			Clerical	$65.71
B. Required activities d
Prepare for periodic performance test	24	1	24	2	48	2.4	4.8	$6,960
Attend periodic performance test	24	2	48	2	96	4.8	9.6	$13,921
C. Create information	See 3B
D. Gather existing information	See 3B
E. Write report
Notification of construction/reconstruction e,f	2	1	2	0	0	0	0	$0
Notification of actual startup e,f	2	1	2	0	0	0	0	$0
Notification of applicability e,f	2	1	2	0	0	0	0	$0
Notification of performance test f,g	2	1	2	2	4	0.2	0.4	$580
Notification of CMS performance evaluation f,g	2	1	2	2	4	0.2	0.4	$580
Notifications for equipment leaks e,f	2	1	2	0	0	0	0	$0
Notifications for wastewater e,f	2	1	2	0	0	0	0	$0
Notification of compliance status g,h	40	1	40	2.7	107	5.3	11	$15,468
Semiannual report - no deviations i	8	2	16	6.4	102	5.1	10	$14,849
Semiannual report - deviations j	16	2	32	1.6	51	2.6	5.1	$7,424
Semiannual report - equipment leaks k	303	2	606	3	1,818	91	182	$263,627
Semiannual report - wastewater	See 4E
Semiannual report - other l	8	2	16	8	128	6.4	13	$18,561
Subtotal for Reporting Requirements					2,737			$345,065
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 failures to meet standards/actions taken to minimize emissions m	2	12	24	0.4	10	0.5	1.0	$1,392
Records of continuous parameters monitoring system (CPMS) data n	1	365	365	8	2,920	146	292	$423,428
Records of closed-loop systems o	2	2	4	1	4	0.2	0.4	$580
Records of nitrogen systems p	2	2	4	5	20	1	2	$2,900
Records of material balances q	8	2	16	5	80	4	8	$11,601
Records of supporting calculations r	8	2	16	8	128	6.4	13	$18,561
Records for equipment leaks	See 3E
All other records	See 3E
F. Time to train personnel
Initial training e,s	40	1	40	0	0	0	0	$0
Refresher training t	16	1	16	8	128	6.4	13	$18,561
G. Time to transmit or disclose information u
Compile data	24	2	48	8	384	19	38	$55,684
Enter and verify information for semiannual report	16	2	32	8	256	13	26	$37,122
H. Time for audits	N/A
Subtotal for Recordkeeping Requirements					4,519			$569,829
TOTAL LABOR BURDEN AND COST					7,256			$914,894					hrs/response	143
TOTAL ANNUALIZED CAPITAL AND O&M COST								$163,533
GRAND TOTAL								$1,078,427
Assumptions:
a We estimate that there are 8 sources that are subject to the standard which includes the following facilities: 3 cellulose ether; 1 cellulosic sponge; 3 cellulose food casing; and 1 cellophane (for a total of 8 respondents). We estimate no new sources will become subject to the rule each year over the 3-year period of this ICR.
b This ICR uses the following labor rates: $163.17 ($77.70 + 110%) per hour for Executive, Administrative, and Managerial labor; $130.28 ($62.04 + 110%) per hour for Technical labor, and $65.71 ($31.29 + 110%) per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2022, “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 have assumed that it will take the respondents 8 hours to familiarize themselves with the regulatory requirements during the three-year period covered by this ICR renewal (8 respondents/3 years = 2.7).
d We estimate that it will take the respondent 24 hours to prepare for periodic performance test (e.g., prepare test plan) and 24 hours to attend the test. We also estimate 2 plant personnel will attend the test.
e These requirements are one-time requirements that apply to new respondents. There are no new respondents estimated over the 3-year period of this ICR.
f We estimate that it will take the respondent 2 hours to complete the notification.
g We estimate that 6 facilities will need to submit notification of performance test, conduct the test, and report the results through CEDRI. No performance test required for the 2 cellulosic sponge and cellophane facilities because these facilities use recovery devices to meet the emission limit. These facilities are required to conduct a compliance demonstration based on the material balance for their process. The periodic testing will occur once during the 3-year ICR period (6 respondents/3 years = 2). All 8 facilities must submit a notification of compliance status with results of the performance test (8 respondents/3 years = 2.7).
h We estimate that it will take each respondent 40 hours to prepare the notification of compliance status.
i We have assumed that 80% of all respondents will report no deviation (0.8 x 8 respondents = 6.4).
j We have assumed that 20% of all respondents will report a deviation (0.2 x 8 respondents = 1.6).
k We estimate that it will take each respondent 303 hours on a semiannual basis to write reports for 3 cellulose ether facilities subject to leak detection and repair (LDAR) requirements.
l 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 for all 8 facilities.
m We have assumed that 5% of respondents will fail to meet standards each year (0.05 x 8 = 0.4). We estimate that each respondent will take 2 hours 12 times per year to keep records of failures to meet the standards and the actions taken to minimize emissions.
n We estimate that it will take each respondent 1 hour to record information on a daily basis on process vent, storage tank and wastewater monitoring and inspections.
o We estimate that it will take each respondent 2 hours to enter information on 1 cellulose ether facility with a closed-loop system.
p We estimate that it will take each respondent 2 hours to enter information on 5 viscose process facilities with CS2, unloading and storage operations.
q We estimate that it will take each respondent 8 hours to enter information on 5 viscose process facilities using material balances.
r We estimate that it will take each respondent 8 hours to enter information on supporting calculations twice per year.
s We estimate that it will take each respondent 1 week (40 hours) to provide initial training to personnel with new sources.
t We estimate that it will take each respondent 2 days (16 hours) to provide refresher training to personnel.
u We have assumed that each respondent will enter and verify information for the semiannual report twice per year.

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Sheet 3: Table 2

Table 2: Average Annual EPA Burden and Cost – NESHAP for Cellulose Products Manufacturing (40 CFR Part 63, Subpart UUUU) (Renewal)
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											Labor Rates
Attend performance test c	24	1	24	0.2	4.8	0.2	0.5	$293			Management	$73.46
Excess emissions enforcement activities d	120	1	120	0.06	7.2	0.4	0.7	$440			Technical	$54.51
Review reports											Clerical	$29.50
Notification of construction/reconstruction e	2	1	2	0	0	0	0	$0
Notification of actual startup e	2	1	2	0	0	0	0	$0
Notification of applicability e	2	1	2	0	0	0	0	$0
Notification of performance test f	2	1	2	2	4	0.2	0.4	$245
Notification of CMS performance evaluation f	2	1	2	2	4	0.2	0.4	$245
Notification of compliance status g	4	1	4	2.7	11	0.5	1.1	$652
Report of performance test h	8	1	8	2	16	0.8	1.6	$978
Report of CMS performance evaluation h	8	1	8	2	16	0.8	1.6	$978
Semiannual report - no deviations i	2	2	4	6.4	26	1.3	2.6	$1,565
Semiannual report - deviations j	8	2	16	1.6	26	1.3	2.6	$1,565
Semiannual report - equipment leaks k	8	2	16	3	48	2.4	4.8	$2,934
Semiannual report - wastewater k	8	2	16	3	48	2.4	4.8	$2,934
Semiannual report - other l	2	2	4	8	32	1.6	3.2	$1,956
TOTAL ANNUAL BURDEN AND COST					278			$14,786
Assumptions:
a We estimate that there are 8 sources that are subject to the standard which includes the following facilities: 3 cellulose ether; 1 cellulosic sponge; 3 cellulose food casing; and 1 cellophane (for a total of 8 respondents). We estimate no new sources will become subject to the rule each year over the 3-year period of this ICR.
b The cost is based on the following labor rate which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses. Managerial rates of $73.456 (GS-13, Step 5, $45.91 + 60%), Technical rate of $54.512 (GS-12, Step 1, $34.07 + 60%), and Clerical rate of $29.504 (GS-6, Step 3, $18.44 + 60%). These rates are from the Office of Personnel Management (OPM), 2023 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 estimate that it will take EPA personnel 24 hours to attend performance tests at 10% of facilities required to test (0.1 x 6 respondents/3 years = 0.2).
d We estimate that 10% of the affected facilities will be required to retest as a result of deviations, and EPA personnel will attend 10% of these tests (0.1 x 0.1 x 6 respondents = 0.06).
e We estimate that it will take EPA personnel 2 hours to complete review of the initial notifications (construction/reconstruction, actual startup, applicability of standard).
f We estimate that it will take EPA personnel 2 hours to complete review of the notifications of performance test and CMS performance evaluation for facilities required to test (6 respondents/3 years = 2).
g We estimate that it will take EPA personnel 4 hours to complete review of the notification of compliance status for all 8 facilities (8 respondents/3 years = 2.7).
h We estimate that it will take EPA personnel 8 hours to complete review of the performance test and CMS performance evaluation data for facilities required to test (6 respondents/3 years = 2).
i We have assumed that 80% of respondents will report no deviations (0.8 x 8 respondents = 6.4) and that it will take EPA personnel 2 hours two times per year to review those reports.
j We have assumed that 20% of respondents will report deviations (0.2 x 8 respondents = 1.6) and that it will take EPA personnel 8 hours two times per year to review those reports.
k We estimate that it will take EPA personnel 8 hours two times per year to review the reports of 3 cellulose ether facilities subject to LDAR and wastewater requirements.
l We estimate that it will take EPA personnel 2 hours two times per year to review all other reports, including changes of information, closed-vent systems, bypass lines, heat exchanger systems, and storage vessel control device maintenance, for all 8 facilities.

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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	Total Capital/Startup Cost, (B X C)	Annual O&M Costs for One Respondent	Number of Respondents with O&M	Total O&M, (E X F)
Continuous Parameter Monitoring System	N/A	N/A	N/A	$78	8	$624
Performance Tests:
Method 15 for total sulfide	$14,000	13	$182,000	N/A	N/A	N/A
Method 18 for organic HAP	$14,000	19	$266,000	N/A	N/A	N/A
Method 25D for wastewater organic HAP	$14,000	3	$42,000	N/A	N/A	N/A
Totals (rounded)			$490,000			$600
Total annualized capital cost b			$163,333			$200		$163,533
b Annualized capital costs were estimated assuming a 5-year payment period at 7% interest for periodic performance tests (with capital recovery factor of 0.2439).

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Sheet 5: Responses

Total Annual Responses
(A)	(B)	(C)	(D)	(E)
Information Collection Activity	Number of Respondents a	Number of Responses	Number of Existing Respondents That Keep Records But Do Not Submit Reports	Total Annual Responses E=(BxC)+D
Notification of performance test	2	1	0	2
Notification of CMS performance evaluation	2	1	0	2
Notification of compliance status	2.7	1	0	2.7
Semiannual report - no deviations	6.4	2	0	12.8
Semiannual report – deviations	1.6	2	0	3.2
Semiannual report - equipment leaks	3	2	0	6
Semiannual report – wastewater	3	2	0	6
Semiannual report - all others	8	2	0	16
			Total	51

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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	8	0	0	8
2	0	8	0	0	8
3	0	8	0	0	8
Average	0	8	0	0	8
a New respondents include sources with constructed and reconstructed affected facilities.