Information Collection Request for the EPA National Performance Track

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Overview

bottom line burden and costs
respondent apps and program
respondents incentives
state apps and program burden
state incentives burden
EPA apps and program
EPA incentives burden
site visits hours
apps and members projections

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Sheet 1: bottom line burden and costs

Table 6.1.a
	Total Burden Hours	Total Costs
Respondents
respondents apps and program 2007-2009	35,412	$2,279,355.33
respondents incentives 2007-2009	(14,617)	-$867,239.15
respondents grand total 2007-2009	20,795	$1,412,116.18
respondents annualized	6,932	$470,705.39
States
states app and program 2007-2009	2,954	$148,261.26
states incentives 2007-2009	(335)	-$16,813.65
states grand total 2007-2009	2,619	$131,447.61
states annualized	873	$43,815.87
Agency
EPA apps and program 2007-2009	15,376	$235,925.23
EPA incentives 2007-2009	-	$0.00
EPA grand total 2007-2009	15,376	$235,925.23
EPA annualized	5,125	$78,641.74
Totals
Grand Total burden respondents and states 2007-2009	23,414	$1,543,563.79
Annualized total burden	7,805	$514,521.26
Total hours from ICR 1949.03	109,661
hours savings for ICR 1949.05	86,247
ICR 1949.02	Hours	Costs
Total Respondent Burden, 2003-2006	328,335	$19,641,888
Annualized Total Respondent Burden	109,445	$6,547,296
ICR 1949.03 CURRENT ACTIVE ICR	Hours	Costs
Total Respondent Burden, 2003-2006	340,317
Annualized Total Respondent Burden	113,439
ICR 1949.05
Total respondents burden 2007-2009	23,414	$1,543,564
Annualized total burden	7,805	$514,521
Total and annualized hour and cost reductions from current to nenewal
Total Hour savings- old ICR to renewal	316,903
Annualized Hour savings- old ICR to renewal	105,634

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Sheet 2: respondent apps and program

Table 6.2: Respondent Application and Program Participation Burden, September 1, 2006 - August 31, 2007
Information Collection Activity	Legal ($90.02/Hour)	Mgr. ($75.02/Hour)	Tech. ($59.00/Hour)	Clerical ($31.49/Hour)	Resp. Hours/Year	Labor Cost/Year	# Resp.	Total Hours/Year	Total Cost/Year
Applications
New Applications	4	4	24	1	33.0	$2,108	110	3,630	$231,842
Renewal Applications	2	4	16	1	23.0	$1,456	185	4,255	$269,288
Program Participation
Performance Report (APR)	0	0.5	7.5	0.5	8.5	$496	414	3,519	$205,243
Site Visit	0	0	32	0	32.0	$1,888	40	1,280	$75,520
TOTAL 2006-2007	6	8.5	79.5	2.5	96.5	$5,947		12,684	$781,892
Table 6.2: Respondent Application and Program Burden, September 1, 2007 - August 31, 2008
Information Collection Activity	Legal ($90.02/Hour)	Mgr. ($75.02/Hour)	Tech. ($59.0/Hour)	Clerical ($31.49/Hour)	Resp. Hours/Year	Labor Cost/Year	# Resp.	Total Hours/Year	Total Cost/Year
Applications
New Applications	4	4	24	1	33.0	$2,108	116	3,828	$244,487
Renewal Applications	2	4	16	1	23.0	$1,456	123	2,829	$179,040
Program Participation
Performance Report (APR)	0	0.5	7.5	0.5	8.5	$496	433	3,681	$214,662
Customer Satisfaction Questionnaire	0	0.5	0	0	0.5	$38	415	208	$15,567
Site Visit	0	0	32	0	32.0	$1,888	44	1,408	$83,072
TOTAL 207-2008	6	9	79.5	2.5	97.0	$5,985		10,338	$736,828
Table 6.2: Respondent Application and Program Burden, September 1, 2008 - August 31, 2009
Information Collection Activity	Legal ($90.02/Hour)	Mgr. ($75.02/Hour)	Tech. ($59.00/Hour)	Clerical ($31.49/Hour)	Resp. Hours/Year	Labor Cost/Year	# Resp.	Total Hours/Year	Total Cost/Year
Applications
New Applications	4	4	24	1	33.0	$2,108	122	4,026	$257,133
Renewal Applications	2	4	16	1	23.0	$1,456	128	2,944	$186,318
Program Participation
Performance Report (APR)	0	0.5	7.5	0.5	8.5	$496	457	3,885	$226,560
Site Visit	0	0	32	0	32.0	$1,888	48	1,536	$90,624
Total 2008-2009	6	8.5	79.5	2.5	96.5	$5,947		12,391	$760,635
Total application and program burden 2007-2009	18	26	239	8	290	$17,878.56	-	35,412	$2,279,355
Annualized Burden	6	9	80	3	97	5,960	-	11,804	$759,785

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Sheet 3: respondents incentives

Table 6.3: Respondent Incentives Burden, 2006-2007
Information Collection Activity	Mgr.	Tech.	Clerical	Resp. Hours/Year	Labor Cost/Year	# Resp.	Total Hours/Year	Total Cost/Year
	$75.02	$59.00	$31.49
MACT Provisions
Reduced Reporting Frequency (with or without P2)	-3	-16	-6.5	-25.5	-$1,373.75	15	-382.5	-$20,606.18
MACT Information Collection Subtotal	-3	-16	-6.5	-25.5	-$1,373.75		-382.5	-$20,606.18
RCRA HW Accumulation
Prior Written Notification to Authorized Regulatory Program of Waste Accumulation in Excess of 90 Days	0	0.5	0	0.50	$29.50	15	7.5	$442.50
Amendment to Contingency Plan	0	0.5	0	0.50	$29.50	15	7.5	$442.50
RCRA HW Accumulation Subtotal	0	1	0	1	$59.00		15.0	$885.00
Less Potential RCRA Transportation Cost Savings	0	0	0	0.00	Colin C. Macdonald: this is not a "labor cost" per se; it will remain constant throughout the ICR, because we don't have numbers to project the future direction of the waste shipping market. -$368.98	15	0.0	-$5,534.70
HW Accumulation Subtotal	0	1	0	1	-$309.98		15.0	-$4,649.70
RCRA Inspection Frequency
Submit permit mod or request for reduced inspections to Director 264.15 & 265.15	0	1	0	1	$59.00	: one time event 5	5.0	$295.00
: ICR 1572.06 baseline is 72.5 hours per year 1.39 hours per inspection 52 insp per year now for PT 1.39 hours per inspection 12 insp per year 16.8 hours per year reduction is 55.7 h ours per year Inspections of container areas 264.74	0	-55.7	0	-55.7	-$3,286.30	5	-278.5	-$16,431.50
: Burden reduction rule cost benefit analysis (71 FR 16862 .25 hours per inspection inspection must occur once per operating day 274 operating days per year PT facilities not considered PT facilities: .25 hours per inspection 12 inspections per year = 3 hours per year reduction 65.5 hours per year Inspections of Tanks 264.195	0	-65.5	0	-65.5	-$3,864.50	5	-327.5	-$19,322.50
: ICR 1572.06 baseline is 26 hrs per year .5 hrs per inspection weekly inspections Now PT facilities .5 hrs per inspection 12 times per year equals 6 hours per year reduction 20 hours per year Inspections of Containment buildings 264.1101	0	-20	0	-20	-$1,180.00	5	-100.0	-$5,900.00
: same rationale as tanks in burden reduction rule Inspections of Areas subject to spills 264.15 & 265.15	0	-65.5	0	-65.5	-$3,864.50	5	-327.5	-$19,322.50
Submit notification of termination of PT membership 264.15	0	0	0	0	$0.00	0	0.0	$0.00
HW Inspection Frequency Subtotal	0	-205.7	0	-205.7	-$12,136.30		-1028.5	-$60,681.50
Total Burden 2006-2007	-3	-220.7	-6.5	-230.2	-$13,820.03		-1396.0	-$85,937.38
Table 6.3: Respondent Incentives Burden, 2007-2008
Information Collection Activity	Mgr.	Tech.	Clerical	Resp. Hours/Year	Labor Cost/Year	# Resp.	Total Hours/Year	Total Cost/Year
	$75.02	$59.00	$31.49
MACT Provisions
Reduced Reporting Frequency (with or without P2)	-3	-16	-6.5	-25.5	-$1,373.75	30	-765.0	-$41,212.35
MACT Information Collection Subtotal	-3	-16	-6.5	-25.5	-$1,373.75		-765.0	-$41,212.35
RCRA HW Accumulation
Prior Written Notification to Authorized Regulatory Program of Waste Accumulation in Excess of 90 Days	0	0.5	0	0.50	$29.50	15	7.5	$442.50
Amendment to Contingency Plan	0	0.5	0	0.50	$29.50	15	7.5	$442.50
RCRA HW Accumulation Subtotal	0	1	0	1	$59.00		15.0	$885.00
Less Potential RCRA Transportation Cost Savings	0	0	0	0.00	Colin C. Macdonald: this is not a "labor cost" per se; it will remain constant throughout the ICR, because we don't have numbers to project the future direction of the waste shipping market. -$368.98	15	0.0	-$5,534.70
HW Accumulation Subtotal	0	1	0	1	-$309.98		15.0	-$4,649.70
RCRA Inspection Frequency
Submit permit mod or request for reduced inspections to Director 264.15 & 265.15	0	1	0	1	$59.00	: one time event 15	15.0	$885.00
: ICR 1572.06 baseline is 72.5 hours per year 1.39 hours per inspection 52 insp per year now for PT 1.39 hours per inspection 12 insp per year 16.8 hours per year reduction is 55.7 h ours per year Inspections of container areas 264.74	0	-55.7	0	-55.7	-$3,286.30	20	-1114.0	-$65,726.00
: Burden reduction rule cost benefit analysis (71 FR 16862 .25 hours per inspection inspection must occur once per operating day 274 operating days per year PT facilities not considered PT facilities: .25 hours per inspection 12 inspections per year = 3 hours per year reduction 65.5 hours per year Inspections of Tanks 264.195	0	-65.5	0	-65.5	-$3,864.50	20	-1310.0	-$77,290.00
: ICR 1572.06 baseline is 26 hrs per year .5 hrs per inspection weekly inspections Now PT facilities .5 hrs per inspection 12 times per year equals 6 hours per year reduction 20 hours per year Inspections of Containment buildings 264.1101	0	-20	0	-20	-$1,180.00	20	-400.0	-$23,600.00
: same rationale as tanks in burden reduction rule Inspections of Areas subject to spills 264.15 & 265.15	0	-65.5	0	-65.5	-$3,864.50	20	-1310.0	-$77,290.00
Submit notification of termination of PT membership 264.15	0	0	0	0	$0.00	0	0.0	$0.00
HW Inspection Frequency Subtotal	0	-205.7	0	-205.7	-$12,136.30		-4119.0	-$243,021.00
Total Burden 2006-2007	-3	-220.7	-6.5	-230.2	-$13,820.03		-4869.0	-$288,883.05
Table 6.3: Respondent Incentives Burden, 2008-2009
Information Collection Activity	Mgr.	Tech.	Clerical	Resp. Hours/Year	Labor Cost/Year	# Resp.	Total Hours/Year	Total Cost/Year
	$75.02	$59.00	$31.49
MACT Provisions
Reduced Reporting Frequency (with or without P2)	-3	-16	-6.5	-25.5	-$1,373.75	45	(1,147.50)	-$61,818.53
MACT Information Collection Subtotal	-3	-16	-6.5	-25.5	-$1,373.75		(1,147.50)	-$61,818.53
RCRA HW Accumulation
Prior Written Notification to Authorized Regulatory Program of Waste Accumulation in Excess of 90 Days	0	0.5	0	0.50	$29.50	15	7.50	$442.50
Amendment to Contingency Plan	0	0.5	0	0.50	$29.50	15	7.50	$442.50
RCRA HW Accumulation Subtotal	0	1	0	1	$59.00		15.00	$885.00
Less Potential RCRA Transportation Cost Savings	0	0	0	0.00	Colin C. Macdonald: this is not a "labor cost" per se; it will remain constant throughout the ICR, because we don't have numbers to project the future direction of the waste shipping market. -$368.98	15	-	-$5,534.70
HW Accumulation Subtotal	0	1	0	1	-$309.98		15.00	-$4,649.70
RCRA Inspection Frequency
Submit permit mod or request for reduced inspections to Director 264.15 & 265.15	0	1	0	1	$59.00	: one time event 15	15.00	$885.00
: ICR 1572.06 baseline is 72.5 hours per year 1.39 hours per inspection 52 insp per year now for PT 1.39 hours per inspection 12 insp per year 16.8 hours per year reduction is 55.7 h ours per year Inspections of container areas 264.74	0	-55.7	0	-55.7	-$3,286.30	35	(1,949.50)	-$115,020.50
: Burden reduction rule cost benefit analysis (71 FR 16862 .25 hours per inspection inspection must occur once per operating day 274 operating days per year PT facilities not considered PT facilities: .25 hours per inspection 12 inspections per year = 3 hours per year reduction 65.5 hours per year Inspections of Tanks 264.195	0	-65.5	0	-65.5	-$3,864.50	35	(2,292.50)	-$135,257.50
: ICR 1572.06 baseline is 26 hrs per year .5 hrs per inspection weekly inspections Now PT facilities .5 hrs per inspection 12 times per year equals 6 hours per year reduction 20 hours per year Inspections of Containment buildings 264.1101	0	-20	0	-20	-$1,180.00	35	(700.00)	-$41,300.00
: same rationale as tanks in burden reduction rule Inspections of Areas subject to spills 264.15 & 265.15	0	-65.5	0	-65.5	-$3,864.50	35	(2,292.50)	-$135,257.50
Submit notification of termination of PT membership 264.15	0	0	0	0	$0.00	0	-	$0.00
HW Inspection Frequency Subtotal	0	-205.7	0	-205.7	-$12,136.30		(7,219.50)	-$425,950.50
Total Burden 2008-2009	-3	-220.7	-6.5	-230.2	-$13,820.03		(8,352.00)	-$492,418.73
Grand Total Incentives Burden 2007-2009	-9.0	-662.1	-19.5	-690.6	-$41,460.08	0.0	(14,617.00)	-$867,239.15
Annualized burden				(230.20)	-$13,820.03	-	(4,872.33)	-$289,079.72
Grand Total apps, prog and incentives burden 2007-2009				(400.60)	-$23,581.52	-	20,795.00	$1,412,116.18
Annualized apps, prog and incentives burden 2007-2009				(133.53)	-$7,860.51	-	6,931.67	$470,705.39
annualized per facility							14.56	$988.88

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Sheet 4: state apps and program burden

Table 6.4: State Application and Program Participation Burden, September 1, 2006 - August 31, 2007
	Tech. ($50.19/Hour)	Respondent Hours/Year	Labor Cost/Year	# Respondents	Total Hours/Year	Total Cost/Year
Applications
Environmental Compliance Screen- applications and renewals	2	2	$100.38	295	590	$29,612
Application Subtotal	2	2	$100.38		590	$29,612
Program Activities
Site Visit	14	14	$702.66	: States projected to attend 75% of site visits 30	420	$21,080
Program Activities Subtotal	14	14	$702.66		420	$21,080
Total 2006-2007	16	16	$803.04		1010	$50,692
Table 6.4: State Application and Program Participation Burden, September 1, 2007 - August 31, 2008
	Tech. ($50.19/Hour)	Respondent Hours/Year	Labor Cost/Year	# Respondents	Total Hours/Year	Total Cost/Year
Applications
Environmental Compliance Screen- applications and renewals	2	2	$100.38	239	478	$23,991
Application Subtotal	2	2	$100.38		478	$23,991
Program Activities
Site Visit	14	14	$702.66	: States projected to attend 75% of site visits 33	462	$23,188
Program Activities Subtotal	14	14	$702.66		462	$23,188
Total 2007-2008	16	16	$803.04		940	$47,179
Table 6.4: State Application and Program Participation Burden, September 1, 2008 - August 31, 2009
	Tech. ($50.19/Hour)	Respondent Hours/Year	Labor Cost/Year	# Respondents	Total Hours/Year	Total Cost/Year
Applications
Environmental Compliance Screen- applications and renewals	2	2	$100.38	250	500	$25,095
Application Subtotal	2	2	$100.38		500	$25,095
Program Activities
Site Visit	14	14	$702.66	: States projected to attend 75% of site visits 36	504	$25,296
Program Activities Subtotal	14	14	$702.66		504	$25,296
Total 2008-2009	16	16	$803.04		1,004	$50,391
Grand Total 2007-2009					2,954	$148,261
Annualized Total					985	$49,420

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Sheet 5: state incentives burden

Table 6.5: State Incentives Burden, 2006 - 2007
Information Collection Activity		Tech.		Resp. Hours/Year	Labor Cost/Year	# Resp.	Total Hours/Year	Total Cost/Year
	$46.70	$50.19	$23.80
MACT Provisions
Review Annual Reports or Annual Certifications (For P2 Facilities)	0.0	Colin C. Macdonald: Beth's ICR, which references 1948.01 -6.0	0.0	-6.0	-301.14	15	-90.0	-$4,517.10
MACT Information Collection Subtotal	0.0	-6.0	0.0	-6.0	-301.14		-90.0	-$4,517.10
RCRA HW Accumulation
Review Notifications of Waste Accumulation in Excess of 90 Days	Colin C. Macdonald: Beth's ICR--prior notification review will be "minimal." 0	0.25	0	0.25	12.55	iec: based on 2006 APR data 15	3.8	Colin C. Macdonald: assumed one-time event $188.21
Review contingency plan		0.25		0.25	12.55	15	3.8	$188.21
HW Accumulation Subtotal [see note]	0.0	0.3	0.0	0.5	25.10		7.5	$376.43
RCRA Inspection Frequency
Review permit mod or request for reduced inspection 264.15 & 265.15	0.0	0.3	0.0	0.3	12.55	5	1.3	$62.74
Notify PT member of approval or denial	0.0	0.3	0.0	0.3	12.55	5	1.3	$62.74
Inspection frequency subtotal [see note]	0.0	0.5	0.0	0.5	25.10		2.5	$125.48
Total Burden 2006-2007	0.0	-5.3	0.0	-5.0	-250.95		-80.0	-$4,015.20
NOTE: Affect on reporting requirements undetermined for this draft (presumed to be reduction)
Table 6.5: State Incentives Burden, 2007 - 2008
Information Collection Activity		Tech.		Resp. Hours/Year	Labor Cost/Year	# Resp.	Total Hours/Year	Total Cost/Year
	$46.70	$50.19	$23.80
MACT Provisions
Review Annual Reports or Annual Certifications (For P2 Facilities)	0.0	Colin C. Macdonald: Beth's ICR, which references 1948.01 -6.0	0.0	-6.0	-301.14	30	-180.0	-$9,034.20
MACT Information Collection Subtotal	0.0	-6.0	0.0	-6.0	-301.14		-180.0	-$9,034.20
RCRA HW Accumulation
Review Notifications of Waste Accumulation in Excess of 90 Days	Colin C. Macdonald: Beth's ICR--prior notification review will be "minimal." 0	0.25	0	0.25	12.55	15	3.8	Colin C. Macdonald: assumed one-time event $188.21
Review contingency plan		0.25		0.25	12.55	15	3.8	$188.21
HW Accumulation Subtotal [see note]	0.0	0.3	0.0	0.5	25.10		7.5	$376.43
RCRA Inspection Frequency
Review permit mod or request for reduced inspection 264.15 & 265.15	0.0	0.3	0.0	0.3	12.55	15	3.8	$188.21
Notify PT member of approval or denial	0.0	0.3	0.0	0.3	12.55	15	3.8	$188.21
Inspection frequency subtotal [see note]	0.0	0.5	0.0	0.5	25.10		7.5	$376.43
Total Burden 2007-2008	0.0	-5.3	0.0	-5.0	-250.95		-165.0	-$8,281.35
NOTE: Affect on reporting requirements undetermined for this draft (presumed to be reduction)
Table 6.5: State Incentives Burden, 2008 - 2009
Information Collection Activity		Tech.		Resp. Hours/Year	Labor Cost/Year	# Resp.	Total Hours/Year	Total Cost/Year
	$46.70	$50.19	$23.80
MACT Provisions
Review Annual Reports or Annual Certifications (For P2 Facilities)	0.0	Colin C. Macdonald: Beth's ICR, which references 1948.01 -6.0	0.0	-6.0	-301.14	45	-270.0	-$13,551.30
MACT Information Collection Subtotal	0.0	-6.0	0.0	-6.0	-301.14		-270.0	-$13,551.30
RCRA HW Accumulation
Review Notifications of Waste Accumulation in Excess of 90 Days	Colin C. Macdonald: Beth's ICR--prior notification review will be "minimal." 0	0.25	0	0.25	12.55	iec: based on 2006 APR data 15	3.8	Colin C. Macdonald: assumed one-time event $188.21
Review contingency plan		0.25		0.25	12.55	15	3.8	$188.21
HW Accumulation Subtotal [see note]	0.0	0.3	0.0	0.5	25.10		7.5	$376.43
RCRA Inspection Frequency
Review permit mod or request for reduced inspection 264.15 & 265.15	0.0	0.3	0.0	0.3	12.55	15	3.8	$188.21
Notify PT member of approval or denial	0.0	0.3	0.0	0.3	12.55	15	3.8	$188.21
Inspection frequency subtotal [see note]	0.0	0.5	0.0	0.5	25.10		7.5	$376.43
Total Burden 2008-2009	0.0	-5.3	0.0	-5.0	-250.95		-255.0	-$12,798.45
Total Burden 2007-2009	0.0	-10.5	0.0	-10.0	-501.9	0.0	-335.0	-$16,813.65
Annualized Burden	0.0	-3.5	0.0	-3.3	-167.3	0.0	-111.7	-$5,604.55
NOTE: Affect on reporting requirements undetermined for this draft (presumed to be reduction)
: Inspection of Tank Systems (LQGs) 265.195 This ICR has been revised to reflect burden under the existing (i.e., baseline) requirements for daily inspections, as well as the reduced burden for the weekly inspections as specified in the rule. EPA recognizes the uncertainty of estimating facility adoption of the reduced inspection frequency, given a lack of data on the number of tank facilities with automatic leak detection systems. These systems are required for facilities to adopt weekly inspections. To address its uncertainty, EPA performed limited consultations with the Regions and State. It used their feedback as well as its best judgment to perform a bounding analysis to estimate impacts under a low and high adoption rate scenario. From its consultations, EPA found that automatic leak detection systems are not widely used; rather, the majority of facilities use other methods that might not qualify under the rule. In addition, EPA believes that some facilities will continue to conduct daily inspections under the rule, regardless of their automatic leak detection systems, because of standard tank operating procedures and/or a desire to be proactive toward the environment. Hence, EPA has estimated 25% adoption as a lower-bound (i.e., 25% of tank facilities will adopt the reduced inspections) and 50% as an upper-bound. For tank facilities expected to adopt the weekly inspections, the ICR was revised such that hourly burden was reduced from 68.5 hours/facility/year (i.e., 15 minutes/facility/day) under the baseline to 32.58 hours/facility/year under the rule. The 32.58 annual hour estimate was calculated by assuming 19.58 hours/facility/year to inspect tank monitoring and leak detection equipment each operating day (5 minutes/facility/day) and 13 hours/facility/year to conduct weekly inspections of the tank’s aboveground portions and areas immediately surrounding the tank (20 minutes/facility/week). The 32.58-hour per facility annual burden was applied to 25% of facilities under the lower-bound scenario and 50% under the upper-bound scenario. Tank facilities not adopting the reduced inspections were kept at 68.5 hours per year. The revised burden estimates are shown in this exhibit for the low and high scenarios. It was assumed that tanks are in operation 274 days of the year (i.e., 75% of the year), on average. The ICR estimates that there are 1,702 LQG tank facilities in the U.S. In regard to National Performance Track Program, this analysis assumes that no facilities in the program will apply to reduce their inspection frequency. Low: 1,702 High: 1,702 Low: 86,020 High: 101,285 Low: $5,284,208 High: $6,221,938 LQG note from BR rule CBA
: Small Quantity Generator Tanks 265.201(c)(1), (c)(2), (c)(3) EPA assumes that no SQGs will adopt the weekly inspections as specified in the rule. EPA believes that the majority of SQGs do not have secondary containment, automatic leak detection systems, or workplace practices to detect releases, which are required in order to adopt weekly inspections. In regard to National Performance Track Program, this analysis assumes that no facilities in the program will apply to reduce their inspection frequency. Not Applicable Not Applicable SQG note from BR rule

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Sheet 6: EPA apps and program

Table 6.6: EPA Application and Program Participation Burden, September 1, 2006 - August 31, 2007
	Tech. ($46.03/Hour)	Hours/Year	Labor Cost/Year	# Respondents	Total Hours/Year	Total Cost/Year
Applications
Application Compliance Screen	0.8	0.8	$36.82	110	88	$4,051
Evaluation of Application	8	8	$368.24	110	880	$40,506
Notify Applicant of Selection Status	0.25	0.25	$11.51	110	27.5	$1,266
Renewal applications	7	7	$322.21	188	1316	$60,575
Renewal application compliance screen	0.8	0.8	$36.82	188	150.4	$6,923
Application Subtotal	16.85	16.05	$775.61		2462	$113,321
Program Activities
Site Visit	28	28	$1,288.84	40	1120	$51,554
Review Annual Performance Report	4	4	$184.12	414	1656	$76,226
Program Activities Subtotal	32	32	$1,472.96		2776	$127,779
Total 2006-2007	48.85	48.85	$2,248.57		5238	$241,101
Table 6.6: EPA Application and Program Participation Burden, September 1, 2007 - August 31, 2008
	Tech. ($46.03/Hour)	Respondent Hours/Year	Labor Cost/Year	# Respondents	Total Hours/Year	Total Cost/Year
Applications
Application Compliance Screen	0.8	0.8	$36.82	116	92.8	$4,272
Evaluation of Application	8	8	$368.24	116	928	$42,716
Notify Applicant of Selection Status	0.25	0.25	$11.51	116	29	$1,335
Renewal applications	7	7	$322.21	124	868	$39,954
Renewal application compliance screen	0.8	0.8	$36.82	124	99.2	$4,566
Application Subtotal	16.85	16.05	$775.61		2017	$92,843
Program Activities
Site Visit	28	28	$1,288.84	44	1232	$56,709
Review Annual Performance Report	4	4	$184.12	433	1732	$79,724
Program Activities Subtotal	32	32	$1,472.96		2964	$136,433
Total 2007-2008	48.85	48.85	$2,248.57		4981	$229,275
Table 6.6: EPA Application and Program Participation Burden, September 1, 2008 - August 31, 2009
	Tech. ($46.03/Hour)	Respondent Hours/Year	Labor Cost/Year	# Respondents	Total Hours/Year	Total Cost/Year
Applications
Application Compliance Screen	0.8	0.8	$36.82	122	97.6	$4,493
Evaluation of Application	8	8	$368.24	122	976	$44,925
Notify Applicant of Selection Status	0.25	0.25	$11.51	122	30.5	$1,404
Renewal applications	7	7	$322.21	113	791	$36,410
Renewal application compliance screen	0.8	0.8	$36.82	113	90.4	$4,161
Application Subtotal	16.85	16.05	$775.61		1986	$91,393
Program Activities
Site Visit	28	28	$1,288.84	48	1344	$61,864
Review Annual Performance Report	4	4	$184.12	457	1828	$84,143
Program Activities Subtotal	32	32	$1,472.96		3172	$146,007
Total 2008-2009	48.85	48.85	$2,248.57		5158	$237,400
Grand Total 2007-2009					15,376	$707,776
Annualized					5,125	$235,925

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Sheet 7: EPA incentives burden

Table 6.9: EPA Incentives Burden, 2006 - 2007
Information Collection Activity		Tech.		Resp. Hours/Year	Labor Cost/Year	# Resp.	Total Hours/Year	Total Cost/Year
	$46.70	$50.19	$23.80
MACT Provisions
Review Annual Reports or Annual Certifications (For P2 Facilities)	0.0	Colin C. Macdonald: Beth's ICR, which references 1948.01 0.0	0.0	0.0	0.00	15	0.0	$0.00
MACT Information Collection Subtotal	0.0	0.0	0.0	0.0	0.00		0.0	$0.00
RCRA HW Accumulation
Review Notifications of Waste Accumulation in Excess of 90 Days	Colin C. Macdonald: Beth's ICR--prior notification review will be "minimal." 0	0	0	0.00	0.00	iec: based on 2006 APR data 15	0.0	Colin C. Macdonald: assumed one-time event $0.00
Review contingency plan		0		0.00	0.00	15	0.0	$0.00
HW Accumulation Subtotal [see note]	0.0	0.0	0.0	0.0	0.00		0.0	$0.00
RCRA Inspection Frequency
Review permit mod or request for reduced inspection 264.15 & 265.15	0.0	0.0	0.0	0.0	0.00	5	0.0	$0.00
Notify PT member of approval or denial	0.0	0.0	0.0	0.0	0.00	5	0.0	$0.00
Inspection frequency subtotal [see note]	0.0	0.0	0.0	0.0	0.00		0.0	$0.00
Total Burden 2006-2007	0.0	0.0	0.0	0.0	0.00		0.0	$0.00
NOTE: EPA incentives burden projected to be incurred by states
Table 6.9: EPA Incentives Burden, 2007 - 2008
Information Collection Activity		Tech.		Resp. Hours/Year	Labor Cost/Year	# Resp.	Total Hours/Year	Total Cost/Year
	$46.70	$50.19	$23.80
MACT Provisions
Review Annual Reports or Annual Certifications (For P2 Facilities)	0.0	Colin C. Macdonald: Beth's ICR, which references 1948.01 0.0	0.0	0.0	0.00	30	0.0	$0.00
MACT Information Collection Subtotal	0.0	0.0	0.0	0.0	0.00		0.0	$0.00
RCRA HW Accumulation
Review Notifications of Waste Accumulation in Excess of 90 Days	Colin C. Macdonald: Beth's ICR--prior notification review will be "minimal." 0	0	0	0.00	0.00	15	0.0	Colin C. Macdonald: assumed one-time event $0.00
Review contingency plan		0		0.00	0.00	15	0.0	$0.00
HW Accumulation Subtotal [see note]	0.0	0.0	0.0	0.0	0.00		0.0	$0.00
RCRA Inspection Frequency
Review permit mod or request for reduced inspection 264.15 & 265.15	0.0	0.0	0.0	0.0	0.00	15	0.0	$0.00
Notify PT member of approval or denial	0.0	0.0	0.0	0.0	0.00	15	0.0	$0.00
Inspection frequency subtotal [see note]	0.0	0.0	0.0	0.0	0.00		0.0	$0.00
Total Burden 2007-2008	0.0	0.0	0.0	0.0	0.00		0.0	$0.00
NOTE: EPA incentives burden projected to be incurred by states
Table 6.9: EPA Incentives Burden, 2008 - 2009
Information Collection Activity		Tech.		Resp. Hours/Year	Labor Cost/Year	# Resp.	Total Hours/Year	Total Cost/Year
	$46.70	$50.19	$23.80
MACT Provisions
Review Annual Reports or Annual Certifications (For P2 Facilities)	0.0	Colin C. Macdonald: Beth's ICR, which references 1948.01 0.0	0.0	0.0	0.00	45	0.0	$0.00
MACT Information Collection Subtotal	0.0	0.0	0.0	0.0	0.00		0.0	$0.00
RCRA HW Accumulation
Review Notifications of Waste Accumulation in Excess of 90 Days	Colin C. Macdonald: Beth's ICR--prior notification review will be "minimal." 0	0	0	0.00	0.00	iec: based on 2006 APR data 15	0.0	Colin C. Macdonald: assumed one-time event $0.00
Review contingency plan		0		0.00	0.00	15	0.0	$0.00
HW Accumulation Subtotal [see note]	0.0	0.0	0.0	0.0	0.00		0.0	$0.00
RCRA Inspection Frequency
Review permit mod or request for reduced inspection 264.15 & 265.15	0.0	0.0	0.0	0.0	0.00	15	0.0	$0.00
Notify PT member of approval or denial	0.0	0.0	0.0	0.0	0.00	15	0.0	$0.00
Inspection frequency subtotal [see note]	0.0	#REF!	0.0	0.0	0.00		0.0	$0.00
Total Burden 2008-2009	0.0	#REF!	0.0	0.0	0.00		0.0	$0.00
Total Burden 2007-2009	0.0	#REF!	0.0	0.0	0.0	0.0	0.0	$0.00
Annualized Burden	0.0	#REF!	0.0	0.0	0.0	0.0	0.0	$0.00
NOTE: EPA incentives burden projected to be incurred by states
: Inspection of Tank Systems (LQGs) 265.195 This ICR has been revised to reflect burden under the existing (i.e., baseline) requirements for daily inspections, as well as the reduced burden for the weekly inspections as specified in the rule. EPA recognizes the uncertainty of estimating facility adoption of the reduced inspection frequency, given a lack of data on the number of tank facilities with automatic leak detection systems. These systems are required for facilities to adopt weekly inspections. To address its uncertainty, EPA performed limited consultations with the Regions and State. It used their feedback as well as its best judgment to perform a bounding analysis to estimate impacts under a low and high adoption rate scenario. From its consultations, EPA found that automatic leak detection systems are not widely used; rather, the majority of facilities use other methods that might not qualify under the rule. In addition, EPA believes that some facilities will continue to conduct daily inspections under the rule, regardless of their automatic leak detection systems, because of standard tank operating procedures and/or a desire to be proactive toward the environment. Hence, EPA has estimated 25% adoption as a lower-bound (i.e., 25% of tank facilities will adopt the reduced inspections) and 50% as an upper-bound. For tank facilities expected to adopt the weekly inspections, the ICR was revised such that hourly burden was reduced from 68.5 hours/facility/year (i.e., 15 minutes/facility/day) under the baseline to 32.58 hours/facility/year under the rule. The 32.58 annual hour estimate was calculated by assuming 19.58 hours/facility/year to inspect tank monitoring and leak detection equipment each operating day (5 minutes/facility/day) and 13 hours/facility/year to conduct weekly inspections of the tank’s aboveground portions and areas immediately surrounding the tank (20 minutes/facility/week). The 32.58-hour per facility annual burden was applied to 25% of facilities under the lower-bound scenario and 50% under the upper-bound scenario. Tank facilities not adopting the reduced inspections were kept at 68.5 hours per year. The revised burden estimates are shown in this exhibit for the low and high scenarios. It was assumed that tanks are in operation 274 days of the year (i.e., 75% of the year), on average. The ICR estimates that there are 1,702 LQG tank facilities in the U.S. In regard to National Performance Track Program, this analysis assumes that no facilities in the program will apply to reduce their inspection frequency. Low: 1,702 High: 1,702 Low: 86,020 High: 101,285 Low: $5,284,208 High: $6,221,938 LQG note from BR rule CBA
: Small Quantity Generator Tanks 265.201(c)(1), (c)(2), (c)(3) EPA assumes that no SQGs will adopt the weekly inspections as specified in the rule. EPA believes that the majority of SQGs do not have secondary containment, automatic leak detection systems, or workplace practices to detect releases, which are required in order to adopt weekly inspections. In regard to National Performance Track Program, this analysis assumes that no facilities in the program will apply to reduce their inspection frequency. Not Applicable Not Applicable SQG note from BR rule

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Sheet 8: site visits hours

	respondent	state	EPA
planning	1	1	2
preparation	8	2	2
conducting	20	8	16
write-up	2	2	6
follow up	1	1	2
totals	32	14	28

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Sheet 9: apps and members projections

		Summary Recruitment Table National Environmental Performance Track
Year	2000	2001			2002			2003			2004			2005			2006			2007			2008			2009
Round	1	2	3	total	4	5	total	6	7	total	8	9	total	10	11	total	12	13	total	14	15	total	16	17	total	16	17	total
Applications Received	252	32	50	82	28	59	87	35	56	91	31	65	96	49	51	100			105			110			116			122
Cumulative Applications received	252	284	334	334	362	421	421	456	512	512	543	608	608	657	708	708			813			923			1039			1161
Applications accepted	228	25	32	57	23	37	60	25	39	64	19	54	73	39	37	76			78			82			86			90
eligible renewals																			128			185			123			128
Cum. Applications Accepted	228	253	285	285	308	345	345	370	409	409	428	482	482	521	558	558			636			717			803			893
Membership	228	252	282	282	299	315	315	322	345	345	345	352	352	377	410	401	414		427	433		440	457		475	493		512
Acceptance Rate per round	90%	78%	64%	70%	82%	63%	69%	71%	70%	70%	61%	83%	76%	80%	73%	76%			74%			74%			74%			74%
Applications received - variation by Round - (percent change over applications received in prior round)		-87%	56%	-67%	-44%	111%	6%	-41%	60%	5%	-45%	110%	5%	-25%	4%	4%			5%			5%			5%			5%
Applications Received - Growth by Membership (Percent change over membership of previous round)		14%	20%	36%	10%	20%	31%	11%	17%	29%	9%	19%	28%	14%	14%	28%			26%			26%			26%			26%
Member growth (percent change over prior round)		11%	12%	24%	6%	5%	12%	2%	7%	10%	0%	2%	2%	7%	9%	14%			6%			3%			8%			8%
Withdrawals		1	2	3	6	21	27	18	16	34	1	7	8	3	1	13			15			15			15			15
non-renewals																			37			54			36			37
projected renewals				0			0			0	18	40	58	11	3	14			91			131			87			91
Withdrawals - percent of membership		0%	1%	1%	2%	7%	10%	6%	5%	11%	0%	2%	2%	1%	0%	4%
average mem growth per year (number)	35			54			33			30			7			49
note: the totals for cumulative membership and withdrawals are a snapshot of totals on the day the latest round is accepted in the program (90 days after the close of the recruitment period, so even numbered rounds are January 29, and odd numbered rounds are July 29). This snapshot shifts starting in 2006 for rounds 12 & 13, to January 29 and August 29)