TABLE 1: |
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Annual Respondent Burden and Cost - NSPS for the Surface Coating of Plastic Parts for Business Machines |
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(40 CFR part 60, subpart TTT) |
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REPORTING/RECORDKEEPING REQUIREMENT |
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(A) Respondent Hours per Occurence (Technical hours) |
(B) Number of Occurences per Respondent per Year |
(C) Hours per Respondent per Year (C=A x B) |
(D) Number of Respondents per Year |
(E) Technical Hours per Year @ $97.88 (E=C x D) |
(F) Management Hours per Year @ $115.40 (F= E x 0.05) |
(G) Clerical Hours per Year @ $48.38 (G= E x 0.1) |
Total Labor Costs per Year |
1. |
APPLICATIONS |
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N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
2. |
SURVEY AND STUDIES |
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N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
3. |
REPORTING REQUIREMENTS |
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New Sourcesa |
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a. |
Read Instructionsb |
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1 |
1 |
1 |
0 |
0 |
0 |
0 |
$0.00 |
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b. |
Required Activities |
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Initial Performance Testsc |
3 |
1 |
3 |
0 |
0 |
0 |
0 |
$0.00 |
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Demonstration of CMS |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
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Repeat of Performance Testsd |
3 |
0.2 |
0.5 |
0 |
0 |
0 |
0 |
$0.00 |
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Method 24 Testinge&f |
78 |
4 |
313 |
0.001 |
0.31 |
0.016 |
0.031 |
$33.96 |
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c. |
Create Information |
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------------------------Included in 3b---------------------------- |
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d. |
Gather Existing Information |
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------------------------Included in 3e---------------------------- |
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e. |
Write Report |
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Notification of Construction/Reconstructiong |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0.00 |
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Notification of Actual Startupg |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0.00 |
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Notification of Initial Performance Testg |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0.00 |
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Report of Performance Test |
5.2 |
1 |
5.2 |
0 |
0 |
0 |
0 |
$0.00 |
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Quarterly Report of Noncomplianceh |
14 |
4 |
56 |
2 |
111 |
5.6 |
11.1 |
$12,075.18 |
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Semiannual Report of Compliancei |
0.4 |
2 |
0.87 |
10 |
8.7 |
0.43 |
0.87 |
$943.37 |
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Total Reporting Hours by Labor Category |
120.3 |
6.0 |
12.0 |
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TOTAL REPORTING BURDEN |
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138 |
Hours |
$13,053 |
4. |
RECORDKEEPING REQUIREMENTS |
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a. |
Read Instructions |
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------------------------Included in 3a---------------------------- |
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b. |
Plan Activities |
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------------------------Included in 3b---------------------------- |
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c. |
Implement Activities |
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------------------------Included in 3b---------------------------- |
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d. |
Develop Record System |
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1 |
1 |
1 |
0 |
0 |
0 |
0 |
$0.00 |
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e. |
Time to Enter Information |
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Record of monthly performance testsi&j |
6 |
12 |
73 |
10 |
730 |
37 |
73 |
$79,243.39 |
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f. |
Train Personnel |
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N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
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g. |
Audits |
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N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
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Total Recordkeeping Hours by Labor Category |
730.4 |
36.5 |
73.0 |
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TOTAL RECORDKEEPING BURDEN |
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840 |
Hours |
$79,243 |
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Total Hours by Labor Category |
850.7 |
42.5 |
85.1 |
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TOTAL ANNUAL LABOR BURDEN AND COST |
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978 |
Hours |
$92,296 |
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Assumptions |
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a. Number of new facilities (per year): 0 |
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b. Technical hours required to read instructions: 1 |
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c. Technical hours required to complete performance test: 3 |
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d. Rate of failed performance tests: 20% |
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e. Technical hours required to complete Method 24: 78. It is assumed the EPA Reference Method 24 test performed on the coatings used by the respondents is generally done by the coatings manufacturers, who provide the test results to the respondents. |
f. It is assumed that 0.1% of all respondents must generate Method 24 data for a coating because they modify the coatings. This situation is assumed to occur 4 times per year. |
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g. Technical hours required for notification preparation: 2 |
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h. It is assumed that 20% of all NSPS facilities report non-compliance each year. |
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i. Number of affected facilities (per year): 10 |
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j. Technical hours required to record monthly performance tests: 6 |
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TABLE 2: |
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Annual Agency Burden and Cost - NSPS for the Surface Coating of Plastic Parts for Business Machines |
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(40 CFR part 60, subpart TTT) |
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REPORTING/RECORDKEEPING REQUIREMENT |
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(A) EPA Hours per Occurence (Technical hours) |
(B) Number of Occurences per Plant per Year |
(C) EPA Hours per Year (C=A x B) |
(D) Plants per Year |
(E) Technical Hours per Year @ $45.52 (E=C x D) |
(F) Management Hours per Year @ $61.36 (F= E x 0.05) |
(G) Clerical Hours per Year @ $24.64 (G= E x 0.1) |
Costs per Year |
INITIAL PERFORMANCE TESTSb |
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New Planta |
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3 |
1 |
3 |
0 |
0 |
0 |
0 |
$0.00 |
REPEAT PERFORMANCE TEST |
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New Planta |
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3 |
0.2 |
0.5 |
0 |
0 |
0 |
0 |
$0.00 |
REPORT REVIEW |
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New Planta |
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Notification of Constructionc |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0.00 |
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Notification of Initial Startupd |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0.00 |
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Notification of Actual Startupd |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0.00 |
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Notification of Initial Testd |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0.00 |
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Review Test Resultse |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0.00 |
QUARTERLY REPORTS OF NONCOMPLIANCE |
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7 |
4 |
28 |
2 |
56 |
2.8 |
5.6 |
$2,841.15 |
SEMIANNUAL REPORTS OF COMPLIANCEf |
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0.4 |
2 |
0.9 |
10 |
9 |
0.4 |
0.9 |
$443.93 |
TOTAL ANNUAL HOURS |
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64.3 |
3.2 |
6.4 |
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SALARY BURDEN (per year) |
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$3,285.08 |
ANNUAL TRAVEL EXPENSESg&h |
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(1 person x 1 plants/year x 3 d/plant x $75 per diem) + ($350 round trip/plant x 1 plant/yr) = |
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$575.00 |
TOTAL ANNUAL BURDEN |
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$3,860.08 |
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Assumptions |
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a. Number of new facilities (per year): 0 |
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b. Technical hours required to complete performance test: 3 |
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c. Technical hours required to review construction notification: 2 |
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d. Technical hours required to review startup and initial test notifications: 2 |
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e. Technical hours required to review performance test results: 3 |
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f. It is assumed that 20% of all NSPS facilities report non-compliance each year. |
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g Percentage of plant visits (per year): 10% |
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h. Round trip airfare to visit plant: $350 |
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