TABLE
1.
AVERAGE
ANNUAL
EPA
BURDEN
AND
COST
(
A)
(
B)
(
AxB=
C)
(
D)
(
E=
CxD)

EPA
hrs/
Occurrences/
EPA
hrs/
Plants/
a
EPA
hrs
Activity
Occurrence
plant/
yr
plant/
yr
year
__________________________________________________________________________________________________

New
Sources:
a
Notification
requirements
Not
Applicable
Initial
performance
test
Not
Applicable
Repeat
performance
test
Not
Applicable
Review
test
results
Not
Applicable
Existing
Sources
Review
semi­
annual
exceedance
rpt.
b
5
2
10
14.3
143.3
Review
annual
rpt
of
formulation/
5
1
5
43
215.0
Method
24
c
Review
report
of
change
in
operating
4
1
4
4.3
17.2
parameters
d
Method
25
A
e
8
1
8
1
8
TOTAL
ANNUAL
HOURS
383.5
Travel
Expenses
f
(
1
person
x
1
plant/
yr
x
1
day/
plant
x
$
85
per
diem/
day.
person)
+
($
350
round
trip/
plant
x
1
plant/
yr)
=
$
435.00
Salary
Total:
(
383.5
hrs
x
$
36.97/
peson­
hr)
=
$
14,178
TOTAL
ANNUAL
COST=
$
14,613
____________________________________________________________________________________________________________

Assumptions:

a
Assume
there
are
43
rubber
tire
manufacturing
plants,
one
of
which
only
mixes
rubber
compound.
Also,
that
there
will
be
no
industry
growth
in
the
next
three
years.

b
Exceedance
reports
submitted
as
applicable.
Assume
one­
third
of
sources
(
or
14.3)
report
exceedance
reports
for
each
six
month.

c
Assume
that
all
existing
plants
submit
this
annual
Method
24
report.
Further
assume
that
50
percent
of
the
existing
plants
will
continue
to
use
HAP
materials
(
VOC)
in
the
spray
at
levels
that
meet
the
green
tire
VOC
limitations
in
NSPS
not
needing
add
on
control
devices.
The
remaining
plants
use
only
water­
based
sprays.

d
Assume
that
10
percent
of
all
sources
(
or
4.3)
will
have
to
report
changes
on
operational
parameters.

e
Assume
there
are
3
plants
that
conduct
Method
25
once
a
year
to
determine
the
VOC
concentration
in
each
stack,
both
entering
and
leaving
the
control
device.
Assume
that
the
Agency
will
attend
one
test
at
a
plant
per
year.
f
Assume
an
hourly
labor
rate
at
GS­
12,
Step
1
times
a
1.6
benefits
multiplication
factor
to
account
for
government
overhead
expenses
for
a
total
of
$
36.97.
