| Burden Item |
A |
B |
C |
D |
E |
F |
G |
H |
|
|
$103.97 |
| Hours per occurrence |
Occurrences per respondent per year |
Hours per respondent per year |
Respondents per yeara |
Technical hours per year |
Management hours per year |
Clerical hours per year |
Total cost per year ($)b |
|
|
$129.93 |
|
|
(AxB) |
|
(CxD) |
(Ex0.05) |
(Ex0.10) |
|
|
|
$51.79 |
| 1. Applications |
N/A |
|
|
|
|
|
|
|
|
|
|
| 2. Survey and Studies |
N/A |
|
|
|
|
|
|
|
|
|
|
| 3. Reporting Requirements |
|
|
|
|
|
|
|
|
|
|
|
| A. Familiarization with the regulatory requirementsc |
1 |
1 |
1 |
28,012 |
0 |
28,012 |
0 |
$3,639,599.16 |
|
|
|
| B. Required activities |
N/A |
|
|
|
|
|
|
|
|
|
|
| C. Create Information |
N/A |
|
|
|
|
|
|
|
|
|
|
| D. Gather existing information |
|
|
|
|
|
|
|
|
|
|
|
| Initial report information |
2 |
1 |
2 |
2,330 |
4,660 |
233 |
466 |
$538,908.03 |
|
|
|
| Solvent consumption |
1 |
1 |
1 |
2,330 |
2,330 |
116.5 |
233 |
$269,454.02 |
|
|
|
| Compliance method reportd |
1 |
1 |
1 |
1,631 |
1,631 |
81.55 |
163.1 |
$188,617.81 |
|
|
|
| E. Write Report |
|
|
|
|
|
|
|
|
|
|
|
| Initial notification report |
1 |
1 |
1 |
2,330 |
2,330 |
116.5 |
233 |
$269,454.02 |
|
|
|
| Compliance method reportc, d |
1 |
1 |
1 |
1,631 |
0 |
1,631 |
0 |
$211,915.83 |
|
|
|
| Solvent consumption reportc, e |
0.25 |
1 |
0.25 |
699 |
0 |
174.75 |
0 |
$22,705.27 |
|
|
|
| Report-exceed consumption cutoffc, f |
1 |
1 |
1 |
117 |
0 |
117 |
0 |
$15,201.81 |
|
|
|
| Reporting Subtotal |
|
|
|
|
42,528 |
$5,155,855.94 |
|
|
|
| 4. Recordkeeping Requirements |
|
|
|
|
|
|
|
|
|
|
|
| A. Familiarization with the regulatory requirements |
See 3A |
|
|
|
|
|
|
|
|
|
|
| B. Plan activitiesg |
1 |
1 |
1 |
2,330 |
2,330 |
0 |
0 |
$242,250.10 |
|
|
|
| C. Implement activities |
|
|
|
|
|
|
|
|
|
|
|
| Above consumption cutoff: Weekly LDARg, h, i |
0.75 |
52 |
39 |
19,600 |
764,400 |
0 |
0 |
$79,474,668.00 |
|
|
|
| Below consumption cutoff: Bi-weekly LDARg, i, j |
0.75 |
26 |
19.5 |
8,400 |
163,800 |
0 |
0 |
$17,030,286.00 |
|
|
|
| Major: Monthly enhanced LDARk, l |
1 |
48 |
48 |
12 |
576 |
28.8 |
57.6 |
$66,611.81 |
|
|
|
| Major: Weekly Carbon adsorber monitoringl, m |
0.25 |
208 |
52 |
12 |
624 |
31.2 |
62.4 |
$72,162.79 |
|
|
|
| Area: Monthly enhanced LDARn, o |
0.75 |
12 |
9 |
20,000 |
180,000 |
9,000 |
18,000 |
$20,816,190.00 |
|
|
|
| D. Develop record system |
|
|
|
|
|
|
|
|
|
|
|
| Solvent consumptiong |
1 |
1 |
1 |
2,330 |
2,330 |
0 |
0 |
$242,250.10 |
|
|
|
| Enhanced LDARg |
1 |
1 |
1 |
2,330 |
2,330 |
0 |
0 |
$242,250.10 |
|
|
|
| Monitoring recordsd, g |
1 |
1 |
1 |
1,631 |
1631 |
0 |
0 |
$169,575.07 |
|
|
|
| Carbon adsorber monitoring recordsp |
1 |
1 |
1 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| E. Time to enter information |
|
|
|
|
|
|
|
|
|
|
|
| Monthly records of solvent consumptionq, r, s |
0.25 |
12 |
3 |
28,012 |
84,036 |
9 |
0 |
$8,738,392.29 |
|
|
|
| Above consumption cutoff: Records of weekly inspectionsh, i, s |
0.25 |
52 |
13 |
19,600 |
254,800 |
39 |
0 |
$26,496,623.27 |
|
|
|
| Below consumption cutoff: Records of bi-weekly inspectionsg, i, j |
0.25 |
26 |
6.5 |
8,400 |
54,600 |
0 |
0 |
$5,676,762.00 |
|
|
|
| Major: Enhanced LDAR |
See 4C |
|
|
|
|
|
|
|
|
|
|
| Major: Carbon adsorber monitoring |
See 4C |
|
|
|
|
|
|
|
|
|
|
| Area: Enhanced LDAR |
See 4C |
|
|
|
|
|
|
|
|
|
|
| F. Time to Train personnel |
|
|
|
|
|
|
|
|
|
|
|
| Leak detectiont, u |
1 |
2 |
2 |
2,330 |
4,660 |
4,660 |
0 |
$1,089,974.00 |
|
|
|
| G. Time for audits |
N/A |
|
|
|
|
|
|
|
|
|
|
| Recordkeeping Subtotal |
|
|
|
|
1,548,005 |
$160,357,995.53 |
|
|
|
| TOTAL ANNUAL BURDEN AND COSTS (rounded): v |
|
|
|
|
1,590,000 |
$166,000,000 |
|
|
|
| Capital and O&M Cost (see Section 6(b)(iii)): v |
|
|
|
|
|
|
|
947,000 |
|
|
|
| TOTAL COST: v |
|
|
|
|
|
|
|
167,000,000 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
52 |
hrs/resp (rounded) |
|
|
| a We have assumed that there are 28,000 existing area sources and that 2,330 sources will leave the industry and will be replaced by 2,330 new area sources over the next three years. We have also assumed that there are 12 existing major sources and that no additional major sources will be subject to the NESHAP over the three-year period of this ICR. |
|
|
|
|
|
|
|
|
|
|
|
| b This ICR uses the following labor rates: Technical $103.97 ($49.51 + 110%); Managerial $129.93 ($61.87+ 110%); and Clerical $51.79 ($24.66 + 110%). 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. This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. |
|
|
|
|
|
|
|
|
|
|
|
| c This task requires management hours only. |
|
|
|
|
|
|
|
|
|
|
|
| d This is based on the estimate that 1,631 (70 percent) of the 2,330 new facilities will be above the cutoff and thus required to perform this task. |
|
|
|
|
|
|
|
|
|
|
|
| e This is based on the estimate that 699 (30 percent) of the 2,330 new facilities will be below the cutoff and thus required to perform this task. |
|
|
|
|
|
|
|
|
|
|
|
| f We estimate that 5 percent of new facilities each year will exceed the cutoff, thus requiring submission of the exceed-consumption cutoff report. |
|
|
|
|
|
|
|
|
|
|
|
| g This task requires only technical employee hours. |
|
|
|
|
|
|
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|
|
| h Occurrences are based on weekly inspection, assuming 52 weeks per year. |
|
|
|
|
|
|
|
|
|
|
|
| i We have assumed that of 28,000 perchloroethylene dry cleaners 19,600 (70 percent) will be above the per consumption cutoff, which will require that the cleaner conduct weekly leak detection and repair. The remaining 8,400 perchloroethylene dry cleaners will be below the consumption cutoff and are only required to conduct bi-weekly leak detection and repair. |
|
|
|
|
|
|
|
|
|
|
|
| j We have assumed that facilities below cutoff performs leak detection and repairs on a bi-weekly basis. |
|
|
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|
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|
|
|
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|
|
| k Major sources contain an average of four machines. Task requires 1 hour times 4 machines/major source. |
|
|
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|
|
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|
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|
|
| l Approximately 12 existing major sources are subject to the NESHAP. |
|
|
|
|
|
|
|
|
|
|
|
| m Major sources contain an average of four machines. Task requires 0.25 hour times 4 machines/major source. |
|
|
|
|
|
|
|
|
|
|
|
| n Area sources contain an average of one machine. Task requires 0.75 hour times 1 machine/area source. |
|
|
|
|
|
|
|
|
|
|
|
| o Approximately 8,000 existing area sources are located in states that already require enhanced monitoring; therefore, 20,000 existing area sources are subject to the NESHAP's enhanced LDAR program. |
|
|
|
|
|
|
|
|
|
|
|
| p No new major sources are expected for the three-year period of this ICR; therefore, no burden is associated with the development of carbon adsorber monitoring record systems. |
|
|
|
|
|
|
|
|
|
|
|
| q Occurrences are based on twelve months rolling average of PCE consumption, determined once per month. |
|
|
|
|
|
|
|
|
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|
|
| r This is based on 28,000 area sources and 12 major sources performing this task every year. |
|
|
|
|
|
|
|
|
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|
|
| s This task is performed primarily by technical staff. Management hours are only for a limited number of major sources, and we assume only three major sources will require managerial review. |
|
|
|
|
|
|
|
|
|
|
|
| t Estimate includes hours for training one owner/operator and one employee. |
|
|
|
|
|
|
|
|
|
|
|
| u This task requires an equal amount of management and technical employee hours. |
|
|
|
|
|
|
|
|
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|
|
| v Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
|
|
|
|
|
|
|
|
|
|
|
| Burden Item |
A |
B |
C |
F |
G |
H |
|
TECH |
$46.67 |
| EPA technical hrs per occurrence |
Occurrences per yeara |
Technical hrs per year (AxB) |
Management hrs per year (Cx0.05) |
Clerical hrs per year (Cx0.10) |
Total cost per year ($)b |
|
MNG |
$62.90 |
| 1. Report review |
|
|
|
|
|
|
|
CLER |
$25.25 |
| A. Initital notification report |
1 |
2,330 |
2,330 |
116.5 |
233 |
121,952.20 |
|
|
|
| B. Solvent consumption reportc |
1 |
699 |
699 |
34.95 |
69.9 |
36,585.66 |
|
|
|
| C. Report-exceed consumption cutoffd |
1 |
117 |
117 |
5.85 |
11.7 |
6,123.78 |
|
|
|
| D. Compliance method reporte |
1 |
1,631 |
1,631 |
81.55 |
163.1 |
85,366.54 |
|
|
|
| Total Labor Burden and Cost f |
|
|
5,490 |
250,000 |
|
|
|
|
|
|
|
|
|
|
|
|
|
| |
|
|
|
|
|
|
|
|
|
| Assumptions: |
|
|
|
|
|
|
|
|
|
| a We have assumed that there are 28,000 existing area sources and that 2,330 sources will leave the industry and will be replaced by 2,330 new area sources over the next three years. We have also assumed that there are 12 existing major sources and that no additional major sources will be subject to the NESHAP over the three-year period of this ICR. |
|
|
|
|
|
|
|
|
|
| b This cost is based on the average hourly labor rate as follows: Technical $46.67 (GS-12, Step 1, $29.17 + 60%); Managerial $62.90 (GS-13, Step 5, $39.31 + 60%); and Clerical $25.25 (GS-6, Step 3, $15.78 + 60%). This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. These rates are from the OPM, 2015 General Schedule, which excludes locality rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees. |
|
|
|
|
|
|
|
|
|
| c We assume that 30 percent of new sources will consume less than 140 gallons of PCE per year. |
|
|
|
|
|
|
|
|
|
| d We assume that five percent of new sources will have to report-exceed consumption cutoff. |
|
|
|
|
|
|
|
|
|
| e We assume that 70 percent of new area sources will consume between 140 to 200 gallons of PCE per year. |
|
|
|
|
|
|
|
|
|
| f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
|
|
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|