
TABLE
2.
ANNUAL
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
40
CFR
PART
60,
SUBPART
BBB
(
A)
(
B)
(
C=
AxB)
(
D)
(
E=
CxD)
(
F)

Occurrences/
Hours/

Hours/
respondent/
respondent/
Respondents/
Hours/
Cost/
c
occurrence
year
year
year
year
year
Continuation
.
.
.

1.
APPLICATIONS
............................
not
applicable.........................

2.
SURVEYS
AND
STUDIES
............................
not
applicable.........................

3.
REPORTING
REQUIREMENTS
A.
Read
Instructions
Existing
plants
1
1
1
4.3
d
4.3
237.96
B.
Required
Activities
Existing
Plants
a
+
b
Initial
performance
test
240
5
e
1,200
0
0
0
Repeat
of
performance
test
240
1
e
240
0
0
0
C.
Create
Information
See
3B.

D.
Gather
Existing
Information
See
3E.

E.
Write
Report
Existing
Plants
a
+
b
Notification
Requirements:
f
Not
applicable
­
construction/
reconstruction
­
anticipated
startup
­
actual
startup
­
initial
performance
test
­
physical/
operational
changes
Notification
of
Method
25A
test
g
4
1
4
3
12
664.08
Report
of
change
in
operating
parameters
d
4
2
8
4.3
34.4
1,903.70
Report
of
performance
test
See
3B.

Semi­
annual
exceedance
rep.
h
10
2
20
14.3
286.7
15,864.13
Annual
Report
of
formulation
data/
Method
24
results
i
4
1
4
43
172.0
9,518.48
Reporting
Subtotal
509.4
28,188.35
TABLE
2.
ANNUAL
BURDEN
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
NSPS,
SUBPART
BBB
(
A)
(
B)
(
C=
AxB)
(
D)
(
E=
CxD)
(
F)

Occurrences/
Hours/

Hours/
respondent/
respondent/
Respondents/
Hours/
Cost/
b
2
occurrence
year
year
year
year
year
4.
RECORDKEEPING
REQUIREMENTS
Existing
Plants
A.
Read
Instructions
See
3A.

B.
Plan
Activities
See
4C.

C.
Implement
Activities
See
3B.

D.
Develop
Record
System
............................
not
applicable.........................

E.
Time
to
Enter
Information
Records
of
startups,

shutdown,
malfunction,
etc.
0.5
j
36
k
18
43
774.0
42,833.16
Records
of
operating
parameters
1
l
252
m
252
43
10,836.0
599,664.24
Records
of
monthly
performance
test
2
12
24
43
1,032.0
57,110.88
F.
Train
Personnel
............................
not
applicable.........................

G.
Audits
............................
not
applicable.........................

H.
Subtotal
12,642.0
699,608.30
TOTAL
ANNUAL
BURDEN
13,151.4
727,796.63
_______________________________________________________________________________________________________________________

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.
The
reporting
requirements
for
affected
facilities
exemptions
under
40
CFR
§
60.676(
d)
are
not
reflected
in
the
table
because
their
occurrence
is
very
rare
in
practice.

b
Assume
that
none
of
the
existing
facilities
will
either
add
a
new
affected
facility
or
will
conduct
an
operational
change
such
that
it
will
trigger
applicability
of
this
rule.
Affected
facilities
are
those
operations
in
tire
manufacturing
plants
as
described
by
Subpart
BBB.

c
Assume
a
technical
Labor
Rate
of
$
55.34
per
hour.
This
rate
is
from
the
United
States
Department
of
Commerce
Bureau
of
Labor
Statistics,
March
2000,
"
Table
10.
Private
industry,
by
occupational
and
industry
group."
The
rate
is
from
column
1,
"
Total
compensation."
The
wage
rate
have
been
increase
by
110%
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.
This
amount
was
multiplied
by
the
hours
per
year
in
Column
E.

d
Assume
that
ten
percent
of
the
existing
facilities
will
make
a
physical/
operational
change.

e
A
new
plant
typically
would
have
about
5
new
affected
facilities.
However,
we
are
assuming
that
no
new
plants
will
be
built.

f
There
are
no
notification
requirements,
since
there
are
no
new
affected
facilities.

g
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.

h
Exceedance
reports
submitted
as
applicable.
Assume
one­
third
of
sources
report
exceedance
reports
for
each
six
month.

i
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.

j
Assume
that
the
burden
incurred
to
record
these
items
is
1
hour
per
occurrence
per
source
due
to
the
nature
of
the
control
equipment
used
and
its
intermittent
use.

k
Assume
two
occurrences
of
startup,
shutdown
and/
or
malfunction
per
source
per
month
which
yields
an
average
of
18
occurrences
per
source
per
respondent(
36
weeks).

l
Assume
that
the
burden
incurred
to
record
these
times
is
1
hour
per
occurence
since
much
of
the
required
information
3
is
currently
recorded
by
the
industry.

m
Assume
operation
of
252
days
per
year
(
36
weeks).
