| Table 1- Respondent Burden and Cost |
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Hours and Cost per Application |
Total per Respondent |
Total Hours and Cost for industry |
| Information Collection Activity |
Engineer |
Manager |
Legal |
Clerical |
Respon. hr/yr |
Labor Cost/yr |
Capital Startup Cost |
O&M Cost(1) |
Average Frequency (DIRs/VERRs per Respondent) |
Total hr/yr |
Total Cost/yr (Without labor) |
Number of Respondents |
Total hr/yr |
Total Cost/yr |
| $81.35 |
$123.98 |
$130.26 |
$31.35 |
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| Defect Information Reports (DIRs) |
| Review of instructions and regulations |
10 |
8 |
3 |
0 |
21 |
$2,196.12 |
$0.00 |
$0.00 |
1.0 |
21 |
0 |
75 |
1,575 |
$164,709.00 |
| Compile Data |
44 |
12 |
0 |
0 |
56 |
$5,067.16 |
$0.00 |
$40.00 |
3.0 |
168 |
120 |
75 |
12,600 |
$1,149,111.00 |
| Prepare and submit report |
12 |
4 |
2 |
5 |
23 |
$1,889.39 |
$0.00 |
$10.00 |
3.0 |
69 |
30 |
75 |
5,175 |
$427,362.75 |
| Review report |
3.2 |
1.5 |
1 |
1 |
7 |
$607.90 |
$0.00 |
$0.00 |
3.0 |
20 |
0 |
75 |
1,508 |
$136,777.50 |
| Recordkeeping |
1 |
0 |
0 |
2 |
3 |
$144.05 |
$0.00 |
$2.00 |
1.0 |
3 |
2 |
75 |
225 |
$10,953.75 |
| Voluntary Emission Recall Reports (VERRs) |
| Review regulations |
9 |
4 |
1 |
0 |
14 |
$1,358.33 |
$0.00 |
$0.00 |
1.0 |
14 |
0 |
20 |
280 |
$27,166.60 |
| Compile Data |
24 |
5 |
0 |
0 |
29 |
$2,572.30 |
$0.00 |
$40.00 |
2.0 |
58 |
80 |
20 |
1,160 |
$104,492.00 |
| Prepare and submit report |
8 |
5 |
2 |
3 |
18 |
$1,625.27 |
$0.00 |
$10.00 |
2.0 |
36 |
20 |
20 |
720 |
$65,410.80 |
| Review report |
7 |
3 |
1 |
1 |
12 |
$1,103.00 |
$0.00 |
$0.00 |
2.0 |
24 |
0 |
20 |
480 |
$44,120.00 |
| Maintain Owner Records |
2 |
2 |
0 |
40 |
44 |
$1,664.66 |
$0.00 |
$40.00 |
2.0 |
88 |
80 |
20 |
1,760 |
$68,186.40 |
| Voluntary Recall Quarterly Reports |
| Review regulations |
8 |
4 |
1 |
0 |
13 |
$1,276.98 |
$0.00 |
$0.00 |
1.0 |
13 |
0 |
20 |
260 |
$25,539.60 |
| Compile Data |
10 |
1 |
0 |
0 |
11 |
$937.48 |
$0.00 |
$45.00 |
2.0 |
22 |
90 |
20 |
440 |
$39,299.20 |
| Prepare and submit report |
1 |
1 |
0 |
1 |
3 |
$236.68 |
$0.00 |
$5.00 |
2.0 |
6 |
10 |
20 |
120 |
$9,667.20 |
| Review report |
2 |
1 |
1 |
1 |
5 |
$448.29 |
$0.00 |
$0.00 |
2.0 |
10 |
0 |
20 |
200 |
$17,931.60 |
| Recordkeeping - VERRs & VERR Quarterly Reports |
1 |
0 |
0 |
2 |
3 |
$144.05 |
$0.00 |
$2.00 |
1.0 |
3 |
2 |
20 |
60 |
$2,921.00 |
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| Total per manufacturer |
142 |
52 |
12 |
56 |
262 |
$21,271.66 |
0 |
$194.00 |
varies |
555 |
434 |
N/A |
N/A |
N/A |
| Total for the Industry |
N/A |
N/A |
N/A |
N/A |
N/A |
$2,276,608.40 |
$0.00 |
$17,040.00 |
varies |
N/A |
N/A |
75 |
26,563 |
$2,293,648.40 |
| Table 3 - Annual Agency Burden and Cost |
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| Information Collection Activity |
Hours and cost per application |
Total hours and cost |
| Engineer (GS-13/10) |
Engineer (GS-9) |
Attorney (GS-13.10) |
Manager (GS 15) |
SES-1 |
Agency hr/yr |
Labor cost/yr |
Capital Startup Cost |
O&M Costs |
Applications/Respondents |
Number of Respondents |
Total hr/yr |
Total cost/yr |
| $88.74 |
$24.74 |
$88.74 |
$104.37 |
$158.40 |
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| DIRs and VERRs |
| Review regulations |
10.0 |
20.0 |
20.0 |
10.0 |
2.0 |
62.0 |
$2,300.26 |
$0.00 |
$2.00 |
1.0 |
1 |
62 |
$2,302.26 |
| Answer respondent questions |
0.5 |
1.0 |
0.1 |
0.1 |
0.0 |
1.6 |
$48.80 |
$0.00 |
$0.00 |
1.0 |
75 |
120 |
$3,660.36 |
| Review reports for completeness, compliance, etc. |
0.0 |
0.5 |
0.0 |
0.0 |
0.0 |
0.5 |
$0.00 |
$0.00 |
$0.50 |
1.0 |
75 |
38 |
$37.50 |
| Analyze reports, evaluate manufacturer's procedures |
0.5 |
1.0 |
0.3 |
0.3 |
0.0 |
2.1 |
$70.99 |
$0.00 |
$0.00 |
1.0 |
75 |
158 |
$5,324.16 |
| Recommend activities |
1.0 |
1.0 |
0.3 |
0.3 |
0.0 |
2.6 |
$115.36 |
$0.00 |
$0.50 |
1.0 |
75 |
195 |
$8,689.26 |
| Address potential issues |
15.0 |
40.0 |
15.0 |
15.0 |
10.0 |
95.0 |
$5,289.76 |
$0.00 |
$40.00 |
1.0 |
1 |
95 |
$5,329.76 |
| Voluntary Emission Recall Reports (VERRs) |
| Review, and analyze |
1.0 |
1.0 |
1.0 |
1.0 |
0.0 |
4.0 |
$177.47 |
$0.00 |
$0.50 |
1.0 |
20 |
80 |
$3,559.44 |
| Address potential issues |
1.0 |
2.0 |
0.5 |
0.3 |
0.3 |
4.1 |
$194.19 |
$0.00 |
$20.00 |
1.0 |
20 |
82 |
$4,283.74 |
| Data entry and file |
0.0 |
0.0 |
0.0 |
0.0 |
0.0 |
0.0 |
$0.00 |
$0.00 |
$0.00 |
1.0 |
20 |
0 |
$0.00 |
| VERR updates |
| Review, analyze and process |
1.0 |
1.0 |
0.0 |
1.0 |
1.0 |
4.0 |
$440.24 |
$0.00 |
$0.50 |
1.0 |
20 |
80 |
$8,814.80 |
| Address potential issues |
1.0 |
1.0 |
0.0 |
0.5 |
0.0 |
2.5 |
$133.10 |
$0.00 |
$5.00 |
1.0 |
20 |
50 |
$2,762.08 |
| Data entry and file |
0.0 |
0.0 |
0.0 |
0.0 |
0.0 |
0.0 |
$0.00 |
$0.00 |
$0.00 |
1.0 |
20 |
0 |
$0.00 |
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| Subtotal for the agency (EPA Personnel only) |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
$44,126.36 |
$0.00 |
$637.00 |
1.0 |
75 |
959 |
$44,763.36 |
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+ Contractor Services |
899 |
$41,329.84 |
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EPA TOTALS: |
1,858 |
$86,093.20 |