| Table 1: Annual Respondent Burden and Cost – NSPS for Petroleum Dry Cleaners (40 CFR Part 60, Subpart JJJ) (Renewal) |
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103.97 |
129.93 |
51.79 |
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| Burden item |
(A) Person-hours per occurrence |
(B) No. of occurrences per respondent per year |
(C) Person-hours per respondent per year (AxB) |
(D) Respondents per year a |
(E) Technical person-hours per year (CxD) |
(F) Management person-hours per year (Ex0.05) |
(G) Clerical person-hours per year (Ex0.01) |
(H) Cost, $ b |
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| 1. Applications |
N/A |
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| 2. Survey and Studies |
N/A |
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| 3. Reporting Requirements |
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| A. Familiarize with rule requirement |
See 4E |
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| B. Required activities |
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| Initial performance test c, d |
61 |
1 |
61 |
20 |
1,220 |
61 |
122 |
$141,087.51 |
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| Repeat of performance test c, d, e |
61 |
1 |
61 |
4 |
244 |
12.2 |
24.4 |
$28,217.50 |
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| C. Create information |
See 3B |
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| D. Gather existing information |
See 3B |
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| E. Write report |
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| Notification of construction/ modification c, f |
2 |
1 |
2 |
20 |
40 |
2 |
4 |
$4,625.82 |
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| Notification of actual startup c, f |
2 |
1 |
2 |
20 |
40 |
2 |
4 |
$4,625.82 |
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| Notification of initial performance test c , f |
2 |
1 |
2 |
20 |
40 |
2 |
4 |
$4,625.82 |
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| Report of performance test |
See 3B |
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| Subtotal for Reporting Requirements |
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1,822 |
$183,182.47 |
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| 4. Recordkeeping requirements |
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| A. Familiarize with rule requirement |
See 3A |
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| B. Plan activities |
See 4C |
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| C. Implement activities |
See 3B |
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| D. Develop record system |
N/A |
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| E. Time to enter information |
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| Record of all performance tests c, g |
1 |
1.2 |
1.2 |
20 |
24 |
1.2 |
2.4 |
$2,775.49 |
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| F. Time for audits |
N/A |
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| Subtotal for Recordkeeping Requirements |
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28 |
$2,775.49 |
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| TOTAL LABOR BURDEN AND COST (rounded) h |
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1,850 |
$186,000 |
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22 |
hr/resp |
| Capital and O&M Cost (see Section 6(b)(iii)): h |
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$0 |
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| TOTAL COST: h |
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$186,000 |
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| Assumptions: |
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| a We have assumed that there are approximately 1,000 existing sources that are currently subject to the rule with an estimated 20 new additional sources per year over the next three years. The rule stipulates that only new sources with one-time-only requirements are subject to this subpart. We therefore, concluded that the number of respondents for this renewal ICR is 20 sources per year. |
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| b This ICR uses the following labor rates: $129.93 per hour for Executive, Administrative, and Managerial labor; $103.97 per hour for Technical labor, and $51.79 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2014, “Table 2. Civilian Workers, by Occupational and Industry group.” The rates are from column 1, “Total Compensation.” The rates have been increased by 110% to account for the benefit packages available to those employed by private industry. |
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| c This is a one-time only activity. |
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| d We have assumed that it will take 61 hours for each respondent to complete the required activity. |
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| e We have assumed that 20 percent of respondents will have to repeat initial performance tests due to failure. |
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| f We have assumed that it will take 2 hours for respondents to write report. |
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| g We have assumed that it will take each respondent one hour to enter information on all performance tests. |
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| h Totals have been rounded to 3 significant values. Figures may not add exactly due to rounding. |
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| Table 2: Average Annual EPA Burden and Cost - NSPS for Petroleum Dry Cleaners (40 CFR Part 60, Subpart JJJ) (Renewal) |
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46.67 |
62.9 |
25.25 |
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| Activity |
(A) EPA person-hours per occurrence |
(B) No. of occurrences per plant per year |
(C) EPA person-hours per plant per year (AxB) |
(D) Plants per year a |
(E) Technical person-hours per year (CxD) |
(F) Management person-hours per year (Ex0.05) |
(G) Clerical person-hours per year (Ex0.1) |
(H) Cost, $ b |
| 1. Initial performance test |
16 |
1 |
16 |
20 |
320 |
16 |
32 |
$16,748.80 |
| 2 Repeat performance test c, d |
16 |
1 |
16 |
4 |
64 |
3.2 |
6.4 |
$3,349.76 |
| 3. Report review |
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| Notification of construction/reconstruction c |
2 |
1 |
2 |
20 |
40 |
2 |
4 |
$2,093.60 |
| Notification of actual startup c |
1 |
1 |
1 |
20 |
20 |
1 |
2 |
$1,046.80 |
| Initial performance test c, e |
7.5 |
1 |
7.5 |
20 |
150 |
7.5 |
15 |
$7,851.00 |
| Repeat performance test c, f |
7.5 |
1 |
7.5 |
4 |
30 |
1.5 |
3 |
$1,570.20 |
| TOTAL ANNUAL BURDEN AND COST (rounded) g |
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718 |
$32,700 |
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| Assumptions: |
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| a We have assumed that there are approximately 1,000 existing sources that are currently subject to the rule with an estimated 20 new additional sources per year over the next three years. The rule stipulates that only new sources with one-time-only requirements are subject to this subpart. We therefore, concluded that the number of respondents for this renewal ICR is 20 sources per year. |
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| b This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: Managerial rate of $62.90 (GS-13, Step 5, $39.31 + 60%), Technical rate of $46.67 (GS-12, Step 1, $29.17 + 60%), and Clerical rate of $25.25 (GS-6, Step 3, $15.78 + 60%). These rates are from the Office of Personnel Management (OPM) “2011 General Schedule” which excludes locality rates of pay. |
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| c This is a one-time only activity. |
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| d We have assumed that 20 percent of respondents will have to repeat performance test |
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| e We have assumed that each respondent will take 7.5 hours to review the initial performance test report. |
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| f We have assumed that 20 percent of respondents will have to review the repeat performance test report. |
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| g Totals have been rounded to 3 significant values. Figures may not add exactly due to rounding. |
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