1811.12 Burden Table

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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	79
Number of Respondents	25
Total Estimated Burden Hours	4,350
Total Estimated Costs	$554,000
Annualized Capital O&M	$6,110
Form Number	Not Applicable

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Sheet 2: Table 1

Table 1: Annual Respondent Burden and Cost – NESHAP for Polyether Polyols Production (40 CFR Part 63, Subpart PPP) (Renewal)										Source Type	No.
										Existing	25
										New	0.33
Burden item	A	B	C	D	E	F	G	H
	Person-hours per occurrence	Annual occurrences per respondent	Person-hours per respondent per year (AxB)	Respondents per year a	Technical hours per year (CxD)	Management hours per year (Ex0.05)	Clerical hours per year (Ex0.10)	Annual cost b
1. Applications	N/A									Labor Rates
2. Surveys and studies	N/A									Management	$163.17
3. Reporting requirements										Technical	$130.28
A. Familiarization with Regulatory Requirements	1	1	1	25	25	1.3	2.5	$3,625.24		Clerical	$65.71
B. Required activities
i. Initial performance test: process vents c	480	1	480	0.33	160	8.0	16.0	$23,201.52
ii. Initial performance test: wastewater d	160	1	160	0.33	53	2.7	5.3	$7,733.84
C. Write reports
i. Notification of applicability	2	1	2	0.33	1	0.0	0.1	$96.67
ii. Notification of construction/reconstruction	2	1	2	0.33	1	0.0	0.1	$96.67
iii. Notification of actual startup	2	1	2	0.33	1	0.0	0.1	$96.67
iv. Initial notification e	14	1	14	0.33	5	0.2	0.5	$676.71
v. Performance test notification	2	1	2	0.33	1	0.0	0.1	$96.67
vi. Compliance status notification	2	1	2	0.33	1	0.0	0.1	$96.67
vii. Performance test report	80	1	80	0.33	27	1.3	2.7	$3,866.92
viii. Malfunction report	2	1	2	0	0	0	0	$0.00
ix. Semiannual summary report	20	2	40	25	1,000	50	100	$145,009.50
x. Notification of physical/operational changef	2	1	2	2.50	5	0.3	0.5	$725.05
xi. PRD reporting in semiannual report	5.5	2	11	25	275	13.75	27.5	$39,877.61
Subtotal for Reporting Requirements					1,786			$225,200
4. Recordkeeping requirements
A. Familiarization with Regulatory Requirements	See 3A
B. Develop record system	40	1	40	0.33	13	0.7	1.3	$1,933.46
C. Time to train personnel	40	1	40	0.33	13	0.67	1.3	$1,933.46
D. Continuously monitor parameters	See 3C
E. LDAR program	88	1	88	25	2,200	110.0	220.0	$319,020.90
F. Startup, shutdown, malfunction plan	N/A
Subtotal for Recordkeeping Requirements					2,560			$322,888
TOTAL ANNUAL BURDEN AND COST (Rounded) g					4,350			$548,000		hr/response	79
Capital and O&M Costs (See Section 6(b)(iii)) g								$6,110
TOTAL COST g								$554,000
Assumptions:
a EPA estimates there are 24 existing sources with one new source (or an average of 0.33 sources per year), expected to become subject to the NESHAP over the three-year ICR period, for an overall total average of 25 sources per year.
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 480 hours to complete the initial performance test for process vents.
d We have assumed that it will take 160 hours to complete the initial performance test for wastewater.
e We have assumed that it will take 14 hours to complete the initial notification.
f EPA assumes 10% of existing sources will submit notifications of physical/operational change.
g Totals are rounded to three significant figures. Figures may not add exactly due to rounding.

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Sheet 3: Table 2

Table 2: Average Annual Burden and Cost – NESHAP for Polyether Polyols Production (40 CFR Part 63, Subpart PPP) (Renewal)
Burden item	A	B	C	D	E	F	G	H
	EPA person-hours per occurrence	Annual occurrences per respondent	EPA person-hours per respondent per year (AxB)	Respondents per year a	Technical hours per year (CxD)	Management hours per year (Ex0.05)	Clerical hours per year (Ex0.10)	Annual costb			Labor Rates
Review notification of construction/reconstruction	2	1	2	0.33	1	0.03	0.07	$41			Management	$73.46
Review notification of actual startup	2	1	2	0.33	1	0.03	0.07	$41			Technical	$54.51
Review initial notification report c	8	1	8	0.33	3	0.13	0.27	$163			Clerical	$29.50
Review notification of performance test	4	1	4	0.33	1	0.07	0.13	$82
Review notification of compliance status d	10	1	10	0.33	3	0.17	0.33	$204
Review performance test results	10	1	10	0.33	3	0.17	0.33	$204
Malfunction report	2	1	2	0	0	0	0	$0
Review semiannual summary reports	2	2	4	25	100	5.00	10.00	$6,114
Review notification of physical/operational change	2	1	2	2.50	5	0.25	0.50	$306
TOTAL ANNUAL BURDEN AND COST (ROUNDED) e					135			$7,150
Assumptions:
a EPA estimates there are 24 existing sources with one new source (or an average of 0.33 sources per year), expected to become subject to the NESHAP over the three-year ICR period, for an overall total average of 25 sources per year.
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 $73.46 (GS-13, Step 5, $45.91 + 60%), Technical rate of $54.51 (GS-12, Step 1, $34.07 + 60%), and Clerical rate of $29.50 (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 have assumed that eight respondents will each take 2 hours once per year to review physical/operational changes.
d We have assumed that it will take ten hours once per year to review notification of compliance status.
e Totals are rounded to three 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)				PRD	Process vent monitoring
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)			Term (years)	10	5		2008 CEPCI	2014 CEPCI	2022 CEPCI
Process vent monitoring equipmentb,c	$3,377	0.33	$1,126	$0	24	$0			Interest Rate (%)	8.50%	8.50%	https://fred.stlouisfed.org/series/DPRIME on 2/2/2024	575.4	576.1	816
PRD electronic indicatorsb,d	$14,946	0.33	$4,982	$0	24	$0			CRF	0.15241	0.25377
Totals (rounded) e			$6,110			$0		$6,110
a EPA estimates there are 24 existing sources with one new source (or an average of 0.33 sources per year), expected to become subject to the NESHAP over the three-year ICR period, for an overall total average of 25 sources per year.
b Annual O&M costs are estimated to be negligible and are therefore assumed to be zero.
c We assume existing facilities have already paid off the process vent monitoring equipment. The capital costs for process vent monitoring equipment were estimated to be $69,233 per respondent. We adjusted 2008 $ to 2022 $ using the CEPCI Index. The total capital cost was annualized over five years using a capital recovery factor (CRF) of 0.25377. The resulting cost per respondent per year is $3,377 as shown above.
d Existing sources were required to install PRD monitoring equipment within three years of the final amendment date (March 27, 2014). We assume that all existing facilities have already installed PRD monitoring equipment. The capital costs for PRD were estimated to be $69,233 per respondent. We adjusted 2014 $ to 2022 $ using the CEPCI Index. The total capital cost was annualized over 10 years using a CRF of 0.15241. The resulting cost per respondent per year is $14,946 as shown above.
e Totals are rounded to three significant figures. Figures may not add exactly due to rounding.

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Sheet 5: Responses

Total Annual Responses
(A) Information Collection Activity	(B) Number of Respondents	(C) Number of Responses	(D) Number of Existing Respondents That Keep Records But Do Not Submit Reports	(E) Total Annual Responses E=(BxC)+D
Notification of applicability	0.33	1	0	0.33
Notification of construction/reconstruction	0.33	1	0	0.33
Notification of actual startup	0.33	1	0	0.33
Initial notification	0.33	1	0	0.33
Performance test notification	0.33	1	0	0.33
Compliance status notification	0.33	1	0	0.33
Performance test reports	0.33	1	0	0.33
Startup, shutdown, malfunction reports	0.33	1	0	0.33
Semiannual summary report	25	2	0	50
Notification of physical/operational change	2.50	1	0	2.50
PRD reporting in semiannual report1	25	0	0	0
			Total (rounded)	55
1 Annual occurrences of PRD reporting are not counted as separate responses because they are required to be submitted with the semiannual reports.
			hrs/response:	79

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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	1	24	0	0	25
2	0	25	0	0	25
3	0	25	0	0	25
Average	0.33	25	0	0	25
a New respondents include sources with modified, constructed, and reconstructed affected facilities. Only one new respondent is expected in the next three years affecting this renewal.