Table
2:
Annual
Burden
of
Reporting
and
Recordkeeping
Requirements
under
NESHAP
for
Ethylene
Oxide
Operations
­
Subpart
O
Activity
(
A)
Person
hours
per
Occurrence
(
B)
Number
of
Occurrences
per
respondent
per
year
(
C)
Person
hours
per
respondent
per
year
(
D)
Respondents
per
year
(
E)
Technical
Person­
hours
Per
Year
(
E=
CxD)
(
F)
Management
Person­
hours
Per
Year
(
Ex0.05)
(
G)
Clerical
Person­
hours
Per
Year
(
Ex0.1)
(
H)
Total
Cost
Per
year
1
1.
Applications
Not
Applicable
2.
Surveys
and
Studies
Not
Applicable
3.
Reporting
Requirements
A.
Read
Instructions
1
1
1
22
2
0.1
0.2
73.9
B.
Required
Activities3
Initial
Performance
Test4
200
1
200
2
400
20
40
14780
Repeat
Performance
test
200
0.2
40
0.45
16
0.8
1.6
591.2
C.
Create
Information
on
Performance
Test
Included
in
3B
D.
Gather
Existing
Information
Not
Applicable
E.
Write
Report
i.
Notification
of
Construction/
Reconstruction
2
1
2
2
4
0.2
0.4
147.8
ii.
Notification
of
Anticipated
Startup6
2
1
2
2
4
0.2
0.4
147.8
iii.
Notification
of
Actual
Startup
2
1
2
2
4
0.2
0.4
147.8
iv.
Compliance
Status
Information
Report
2
1
2
100
200
10
20
7390
v.
Notification
of
Initial
Performance
Test
2
1
2
2
4
0.2
0.4
147.8
vi.
Report
of
Initial
Test
Included
in
3B
vii.
Preparation
of
Site­
Specific
(
Performance)
Test
Plan
Included
in
3B
viii.
Reports
of
Periods
of
Noncompliance
6
2
12
100
1200
60
120
44340
ix.
Waiver
Application
6
1
6
0.27
1.2
0.06
0.12
44.3
x.
Alternative
Method/
Monitoring
Application
6
1
6
0.18
0.6
0.03
0.06
22.2
xi.
Request
for
Extension
of
Compliance
and
Progress
Reports
2
1
2
0
9
0
0
0
0
xii.
Reports
of
Excess
Emissions
and
Continuous
Monitoring
System
Performance
Reports/
Summary
Reports
8
1
8
100
800
40
80
29560
4.
Recordkeeping
Requirements
A.
Read
Instructions
Included
in
4E
B.
Plan
Activities
Included
in
4E
C.
Implement
Activities
Included
in
4E
D.
Develop
record
systems
Not
Applicable
1.
Costs
are
based
on
the
following
hourly
rates:
technical
at
$
33,
management
at
$
49,
and
clerical
at
$
15,
plus
110%
overhead
in
Total
Cost.

2.
It
is
anticipated
that
6
new,
modified,
or
reconstructed
facility
will
be
constructed
during
the
period
covered
by
the
Information
Collection
Request.

3.
Assumes
60
person­
hours
pretests/
test
preparation,
60
hours
test,
and
80
hours
analysis
and
report
preparation.

4.
Performance
Test
means
the
initial
performance
test
and
performance
tests
related
to
the
continuous
monitoring
system
5.
It
is
anticipated
that
twenty
percent
of
the
facilities
would
repeat
performance
testing
each
year
(
2
per
year
x
20
percent).

6.
The
term
"
start­
up"
reporting
and
notification
requirements
are
also
referred
to
as
"
initial"
reporting
and
notification
requirements.

7.
Assumes
10
percent
of
facilities
will
request
a
waiver
(
2
per
year
x
10
percent).

8.
Assumes
5
percent
of
facilities
will
apply
for
alternative
method/
monitoring
(
2
per
year
x
5
percent).

9.
Assumes
no
faciity
will
request
an
extension
of
compliance
and
progress
reports.

10.
Table
assumes
an
average
capital/
start­
up
cost
of
$
32500
per
affected
facility
($
32500
x
6
affected
facilities).
This
cost
would
apply
to
new,
modified,
or
reconstructed
facilities.
EPA
does
not
annualize
costs.

11.
Table
assumes
an
average
annual
O&
M
cost
of
$
5500
per
affected
facility
($
5500
x
6
affected
facilities).

E.
Time
to
enter
information
Records
of
Control
Device
Malfunctions,

Maintenance,
Inspections
and
Monitoring
Parameters
(
including
Performance
Testing,
Emission
Testing
and
Cntinuous
monitoring
system
Recordkeeping)
0.1
365
36.5
100
3650
182.5
365
134867.5
G.
Records
of
EO
Use
0.6
12
7.2
12
86.4
4.32
8.64
3192.5
H.
Time
to
Train
Personnel
Not
Applicable
I.
Time
for
Audits
Not
Applicable
SUBTOTAL
(
Labor
Cost
Only)
6372.2
318.61
637.22
494450
5.
Capital/
Start­
up
Cost10
195000
6.
O
&
M
Cost11
33000
TOTAL
ANNUAL
BURDEN
722450
