Table
2:
Annual
Respondent
Burden
and
Cost
Of
Reporting
And
Recordkeeping
Requirements
Of
The
Standards
For
Batch
Vapor
And
In­
Line
Cleaning
Machines
Activity
(
A)

Person
hours
per
Occurrence
(
B)
Number
of
Occurrences
per
respondent
per
year
(
C)
Person
hours
per
respondent
per
yeara
C=
A*
B
(
D)
Respondents
per
yearb
(
E)

Total
Hours
Per
Year
E=
C*
D
(
F)
Total
Cost
Per
year
1.
Applications
Not
Applicable
2.
Surveys
and
Studies
Not
Applicable
3.
Reporting
Requirements
A.
Read
Instructions
2.00
1.00
2.00
393
d
786.00
$
31,259.22
B.
Gather
Existing
Information
included
in
3.
C
C.
Write
Report
Initial
Notification
Report
1.00
1.00
1.00
393
d
393.00
$
15,629.61
Initial
Compliance
Report
4.00
1.00
4.00
393
d
1,572.00
$
62,518.44
­­
Performance
Test
Results
30.00
1.00
30
e
39
f
1,170.00
$
46,530.90
Annual
Compliance
Report
1.50
1.00
1.50
1,180.00
1,770.00
$
70,329.90
Exceedance
Report
(
with
Exceedance)
1.00
3
g
3.00
118
h
354.00
$
14,078.58
Exceedance
Report
(
no
Exceedance)
0.50
1
g
0.50
1062
h
531.00
$
21,117.87
4.
Recordkeeping
Requirements
A.
Read
Instructions
Included
in
3.
A
B.
Plan
Activities
1.00
1.00
1.00
393
d
393.00
$
15,629.61
C.
Implement
Activities
Performance
Test
50.00
1.00
50.00
39
f
1,950.00
$
77,551.50
Control
Device
Monitoring
1.64
j
12.00
19.68
590
k
11,611.00
$
461,769.47
Solvent
Consumption
Log
1.50
12.00
18.00
590
i
10,620.00
$
422,357.40
D.
Record
Data
Control
Device
Monitoring
Records
1.2
m
12.00
14.40
590
k
8,496.00
$
337,885.92
Solvent
Emission
Calculation
0.75
12.00
9.00
590
i
5,310.00
$
211.178.70
E.
Time
to
Train
Personnel
Not
applicable
SUBTOTAL
(
labor
cost
only)
44,956.00
$
1,787,900.10
Table
2:
Annual
Respondent
Burden
and
Cost
Of
Reporting
And
Recordkeeping
Requirements
Of
The
Standards
For
Batch
Vapor
And
In­
Line
Cleaning
Machines
Activity
(
A)

Person
hours
per
Occurrence
(
B)
Number
of
Occurrences
per
respondent
per
year
(
C)
Person
hours
per
respondent
per
yeara
C=
A*
B
(
D)
Respondents
per
yearb
(
E)

Total
Hours
Per
Year
E=
C*
D
(
F)
Total
Cost
Per
year
5.
Capital/
Start­
up
Cost
(
Annualized)
1
$
3,078,620.00
6.
O
&
M
Cost2
$
1,012,440.00
TOTAL
ANNUAL
BURDEN
$
5,704,538.02
a
All
tasks
are
assumed
to
be
performed
by
a
technical
person
$
18.94
+
110%
overhead
=
$
39.77.

b
Total
number
of
facilities
estimated
as:
3,069
cleaning
machines/
2.6
cleaning
machines
per
facility
=
1180
facilities.
One­
time
costs
were
averaged
over
three
years.

1180
facilities
/
3
years
=
393
facilities/
year.

c
Costs
were
calculated
by
multiplying
the
total
number
of
hours
by
the
hourly
wages
noted
in
footnotes
a
and
e
for
column
(
C).

d
One­
time
costs
were
estimated
based
on
1180
facilities
averaged
over
3
years:
1180/
3
years
=
393
facilities/
year.

e
Idling
emission
or
dwell
test
and
report
are
estimated
to
require
70
technical
hours
and
10
managerial
hours
total
(
or
87.5%@$
39.77/
hr
+
12.5%@$
56.63/
hr
=

$
41.86/
hr
average
hourly
rate).
The
hours
were
divided
between
the
test
itself
(
50
hours)
and
the
test
report
(
30
hours).

f
Assumed
that
50%
of
the
facilities
will
choose
the
equipment
standard;
20%
of
those
will
conduct
one­
time
idling
test;
and
one­
time
cost
is
averaged
over
3
years:

50%
x
1180
facilities
x
20%
/
3
years
=
39
facilities.

g
Burden
of
one
quarterly
and
one
semiannual
exceedance
report
was
included
in
the
burden
estimate
for
the
annual
report.

h
Assumed
that
10%
of
the
facilities
are
in
exceedance
one
time
per
year:
10%
x
1180
facilities
=
118
facilities.

i
Activities
planning
is
assumed
to
be
performed
by
a
manager
($
56.63/
hr).

j
Actual
monitoring
is
conducted
weekly,
monthly
or
quarterly
for
specified
control
devices.
This
estimate
includes
weekly,
monthly,
and
quarterly
times
based
on
the
typical
control
devices
expected
to
be
installed.

k
Assumed
that
50%
of
the
facilities
will
choose
the
equipment
standard
and
will
be
required
to
conduct
control
device
monitoring:
50%
x
1180
facilities
=
590
facilities.

l
Assumed
that
50%
of
the
facilities
will
choose
to
do
solvent
consumption
monitoring:
50%
x
1180
facilities
=
590
facilities.

m
Assumed
to
require
20
minutes
per
cleaning
machine,
2.6
machines
per
facility,
and
20
minutes
for
overall
recordkeeping:
[(
0.33
hrs/
cleaner)(
2.6
cleaners/
facility)]
+
0.33
hrs/
facility
=
1.2
hrs/
facility.

n
This
includes
calculations
of
monthly
emissions
and
a
3­
month
rolling
average
emissions
from
solvent
data
o
Assumed
to
be
included
in
facilities'
regular
training
(
no
special
training
required)

p
Assumes
100%
of
facilities
purchase
equipment
to
comply
with
Standard
($
2,609
annualized
cost/
year
x
1180
facilities=
$
3,078,620/
year).
