| Table 1: Annual Respondent Burden and Cost – NESHAP for Paper and Other Web Coating (40 CFR Part 63, Subpart JJJJ) (Renewal) |
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103.97 |
129.93 |
51.79 |
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| Burden item |
(A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
(H) |
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| Person hours per occurrence |
No. of occurrences per respondent per year |
Person hours per respondent per year (C=AxB) |
Respondents per year a |
Technical person- hours per year (E=CxD) |
Management person hours per year (Ex0.05) |
Clerical person hours per year (Ex0.1) |
Cost, $ b |
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| 1. Reporting requirements |
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# New Sources |
6 |
| A. Familiarization with regulatory requirements |
4 |
1 |
4 |
251 |
1004 |
50.2 |
100.4 |
$116,108.08 |
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# Existing Sources |
251 |
| B. Gather information c |
4 |
4 |
16 |
6 |
96 |
4.8 |
9.6 |
$11,101.97 |
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# Existing Sources with Parametric Monitoring |
222 |
| C. Write reports c |
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| i. Initial notification |
2 |
1 |
2 |
6 |
12 |
0.6 |
1.2 |
$1,387.75 |
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| ii. Notification of performance test |
2 |
1 |
2 |
6 |
12 |
0.6 |
1.2 |
$1,387.75 |
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| iii. Notification of compliance status |
2 |
1 |
2 |
6 |
12 |
0.6 |
1.2 |
$1,387.75 |
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| iv. Performance test reports |
2 |
1 |
2 |
6 |
12 |
0.6 |
1.2 |
$1,387.75 |
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| v. SSM reports d |
2 |
0.2 |
0.4 |
222 |
88.8 |
4.44 |
8.88 |
$10,269.32 |
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| vi. Semiannual summary report |
4 |
2 |
8 |
251 |
2008 |
100.4 |
200.8 |
$232,216.16 |
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| Subtotal for Reporting Requirements |
3,732 |
$375,246.52 |
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| 2. Recordkeeping requirements |
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| A. Read instructions c |
4 |
1 |
4 |
6 |
24 |
1.2 |
2.4 |
$2,775.49 |
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| B. Plan activities c |
15 |
1 |
15 |
6 |
90 |
4.5 |
9 |
$10,408.10 |
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| C. Implement activities for compliance coating use e |
5 |
12 |
60 |
21 |
1260 |
63 |
126 |
$145,713.33 |
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| D. Implement activities for control devices and process equipment c |
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| i. Design analysis |
12 |
1 |
12 |
6 |
72 |
3.6 |
7.2 |
$8,326.48 |
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| ii. Performance test oversight |
20 |
1 |
20 |
6 |
120 |
6 |
12 |
$13,877.46 |
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| E. Develop record system |
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| i. Develop startup, shutdown, malfunction plan c |
20 |
1 |
20 |
6 |
120 |
6 |
12 |
$13,877.46 |
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| ii. Develop plan for material used |
10 |
1 |
10 |
21 |
210 |
10.5 |
21 |
$24,285.56 |
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| iii. Control equipment and maintenance plan c |
10 |
1 |
10 |
6 |
60 |
3 |
6 |
$6,938.73 |
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| F. Time to enter information |
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| i. Compliance calculation |
2 |
12 |
24 |
21 |
504 |
25.2 |
50.4 |
$58,285.33 |
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| ii. Control equipment testing |
1 |
1 |
1 |
222 |
222 |
11.1 |
22.2 |
$25,673.30 |
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| G. Time to train personnel |
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| i. Acquisition and installation c |
15 |
1 |
15 |
6 |
90 |
4.5 |
9 |
$10,408.10 |
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| ii. Equipment inspection and monitoring |
10 |
1 |
10 |
222 |
2220 |
111 |
222 |
$256,733.01 |
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| iii. Use of technology and systems f |
10 |
1 |
10 |
222 |
2220 |
111 |
222 |
$256,733.01 |
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| H. Store, file and maintain records g |
0.25 |
12 |
3 |
251 |
753 |
37.65 |
75.3 |
$87,081.06 |
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| I. Retrieve records/reports g |
0.25 |
12 |
3 |
251 |
753 |
37.65 |
75.3 |
$87,081.06 |
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| Subtotal for Recordkeeping Requirements |
10,026 |
$1,008,197.47 |
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| TOTAL LABOR BURDEN AND COST (rounded): |
13,800 |
$1,380,000 |
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| Capital and O&M Cost (see Section 6(b)(iii)): |
$1,010,000 |
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| TOTAL COST: |
$2,390,000 |
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| Assumptions: |
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| a We have assumed that the average number of respondents that will be subject to this rule will be 251. There will be eighteen additional new sources that will become subject to the rule over the three-year period of the ICR (i.e., six 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 percent to account for the benefit packages available to those employed by private industry. |
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| c We have assumed that this is a one-time activity for each new facility. |
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| d Startup, shutdown, malfunction (SSM) reports are to be submitted twice a year with the required semiannual report. However, as estimated 20 percent of the respondents using parametric monitoring will submit an additional report for a non-conforming SSM. |
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| e We have assumed that it would take 21 respondents to record activities for compliance coating use. |
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| f We have assumed that 222 respondents for this activity. |
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| g We have assumed that 251 respondents will be involved in the storage, filing, maintenance and retrieval of records and reports twelve times per year. |
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| Table 2: Average Annual EPA Burden and Cost – NESHAP for Paper and Other Web Coating (40 CFR Part 63, Subpart JJJJ) (Renewal) |
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46.67 |
62.9 |
25.25 |
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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 (C=AxB) |
(D) Respondents per year a |
(E) Technical person- hours per year (E=CxD) |
(F) Management person hours per year (Ex0.05) |
(G) Clerical person hours per year (Ex0.1) |
(H) Cost, $ b |
| 1. Review initial notification c |
8 |
1 |
8 |
6 |
48 |
2.4 |
4.8 |
$2,512.32 |
| 2. Review notification of compliance status |
10 |
1 |
10 |
6 |
60 |
3 |
6 |
$3,140.40 |
| 3. Review SSM reports d |
4 |
ERG:
Corrected frequency to 20% - error in previous ICR renewal
0.2 |
0.8 |
222 |
177.6 |
8.88 |
17.76 |
$9,295.58 |
| 4. Review semiannual summary reports e |
15 |
2 |
30 |
251 |
7530 |
376.5 |
753 |
$394,120.20 |
| 5. Review notification of performance test c |
4 |
1 |
4 |
6 |
24 |
1.2 |
2.4 |
$1,256.16 |
| 6. Review test results c, f |
10 |
1 |
10 |
6 |
60 |
3 |
6 |
$3,140.40 |
| TOTAL ANNUAL BURDEN AND COST (rounded) |
9,080 |
$413,000 |
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| Assumptions: |
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| a We have assumed that the average number of respondents that will be subject to this rule will be 251. There will be eighteen additional new sources that will become subject to the rule over the three-year period of the ICR (i.e., six per year). |
| b This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: $62.90 for Managerial (GS-13, Step 5), $46.67 for Technical (GS-12, Step 1), and $25.25 Clerical (GS-6, Step 3). These rates are from the Office of Personnel Management (OPM) “2014 General Schedule” which excludes locality rates of pay. |
| c We have assumed that this is a one-time activity for each new facility. |
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| d Startup, shutdown, malfunction (SSM) reports are to be submitted twice a year with the required semiannual report. However, as estimated 20 percent of the respondents using parametric monitoring will submit an additional report for a non-conforming SSM. |
| e It is assumed that each respondents will review summary reports twice per year. |
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| f We have assumed that it will take each respondents ten hours to review test results. |
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