|
|
|
|
|
103.97 |
129.93 |
51.79 |
|
|
changes: |
|
| Burden Items |
(A) Respondent Hours per Occurrence |
(B) Number of Occurrences per Respondent per Year |
(C) Hours per Respondent per Year (A x B) |
(D) Number of Respondents per Year a |
(E) Technical Hours per Year (C x D) |
(F) Management Hours per Year (E x 0.05)a |
(G) Clerical Hours per Year (Ex0.1)a |
(H) Total Labor Costs per Year, $b |
|
updated labor rates |
|
|
|
|
|
|
|
|
|
|
|
|
|
| 1. Familiarization with the regulatory requirements |
4 |
1 |
4 |
26 |
104 |
5.2 |
10.4 |
$12,027 |
|
all respondents must refamiliarize |
|
| 2. Required activities |
|
|
|
|
|
|
|
|
|
|
|
| a. Initial performance tests c, d |
8 |
1 |
8 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| b. Engineering calculations or performance guarantees d, e |
8 |
1 |
8 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| c. Continuous parameter monitoring e, f |
8 |
1 |
8 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| 3. Reporting requirements |
|
|
|
|
|
|
|
|
|
|
|
| a. Initial notification that existing facilities are subject to the standard c, g |
4 |
1 |
4 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| b. Notification of new area sources h |
|
|
|
|
|
|
|
|
|
|
|
| (1) Notification of intent to construct/reconstruct |
4 |
1 |
4 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| (2) Notification to commence construct/reconstruct |
4 |
1 |
4 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| (3) Notification of startup |
4 |
1 |
4 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| c. Request for compliance extension h |
4 |
1 |
4 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| d. Notification of initial performance test c, d |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| e. Notification of compliance status c |
4 |
1 |
4 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| f. Gather information for semiannual reports |
4 |
2 |
8 |
26 |
208 |
10.4 |
20.8 |
$24,054.26 |
|
|
|
| g. Semiannual compliance reports i |
4 |
2 |
8 |
26 |
208 |
10.4 |
20.8 |
$24,054.26 |
|
|
|
| Subtotal for Reporting Requirements |
|
|
|
|
598 |
$60,135.66 |
|
|
|
| 4. Recordkeeping Requirements |
|
|
|
|
|
|
|
|
|
|
|
| a. Develop a record system c |
4 |
1 |
4 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| b. Develop a monitoring plan c |
4 |
1 |
4 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| c. Implement activities |
|
|
|
|
|
|
|
$0 |
|
|
|
| (1) Record performance tests |
1 |
1 |
1 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| (2) Record periods of target HAP service and deviations |
0.5 |
52 |
26 |
26 |
676 |
33.8 |
67.6 |
$78,176.36 |
|
|
|
| (3) Continuous parameter monitoring system inspections, calibration and maintenance j |
1 |
12 |
12 |
26 |
312 |
15.6 |
31.2 |
$36,081.40 |
|
|
|
| (4) Vent collection systems and control inspections |
1 |
12 |
12 |
26 |
312 |
15.6 |
31.2 |
$36,081.40 |
|
|
|
| d. Store, file and maintain records |
4 |
1 |
4 |
26 |
104 |
5.2 |
10.4 |
$12,027.13 |
|
|
|
| 5. Time to train personnel |
4 |
1 |
4 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| 6. Prepare for and participate in audits |
0 |
0 |
0 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| Subtotal for Recordkeeping Requirements |
|
|
|
|
1,614.6 |
$162,366.28 |
|
|
|
| TOTAL ANNUAL BURDEN and COST (rounded) k |
|
|
|
|
2,210 |
$223,000 |
|
|
|
| Capital and O&M Cost (see Section 6(b)(iii)): k |
|
|
|
|
|
|
|
$390 |
|
43 |
hr/resp |
| TOTAL COST: k |
|
|
|
|
|
|
|
$223,000 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| Assumptions: |
|
|
|
|
|
|
|
|
|
|
|
| a. We have assumed that there are approximately 26 respondents subject to the rule, with no new sources expected over the next three-years 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. We assume that this is a one-time only activity for new facilities. |
|
|
|
|
|
|
|
|
|
|
|
| d. One-time activity for new and existing facility after promulgation of final rule. Assume that performance tests are not required for any of the existing facilities to demonstrate compliance with the emission limits. We assume that 50 percent of the industry will have existing performance tests that demonstrate compliance with the emission limits, and the other 50 percent will use performance guarantees or engineering calculations to demonstrate compliance. |
|
|
|
|
|
|
|
|
|
|
|
| e. We assume that all existing facilities will use their existing continuous parameter monitoring equipment or alarms to demonstrate continuous compliance. |
|
|
|
|
|
|
|
|
|
|
|
| f. There is no additional burden for new monitoring equipment because additional add-on control devices are not expected to be needed to demonstrate compliance with the emission limits and facilities are already equipped with equipment to monitor existing control device parameters. |
|
|
|
|
|
|
|
|
|
|
|
| g. Existing facilities must submit notification that they are subject to the standard within 120 days of the effective date of final rule. |
|
|
|
|
|
|
|
|
|
|
|
| h We assume that compliance extensions will not be necessary. |
|
|
|
|
|
|
|
|
|
|
|
| i We have assumed that semiannual compliance reports will take each respondent 4 hours twice per year to prepare. |
|
|
|
|
|
|
|
|
|
|
|
| j We have assumed that each respondent will take 1 hour 12 times per year to implement the continuous parameter monitoring system inspections, calibration and maintenance activity. |
|
|
|
|
|
|
|
|
|
|
|
| k Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
46.67 |
62.9 |
25.25 |
|
|
changes: |
| Burden Items |
(A) EPA Hours per Occurrence |
(B) Occurrences per Plant per Year |
(C) EPA Hours per Plant per Year (AxB) |
(D) Plants per Year a |
(E) Technical EPA Hours per Year (CxD) |
(F) Managerial Hours per Year (Ex0.05) |
(G) Clerical Hours per Year (Ex0.1) |
(H) Cost per year, $b |
|
updated labor rates |
| 1. Familiarization with the regulatory requirements |
2 |
1 |
2 |
1 |
2 |
0.1 |
0.2 |
$104.68 |
|
assume that agency would need to refamiliarize once a year (not once per respondent) |
| 2. Required activities |
|
|
|
|
|
|
|
|
|
|
| a. Initial performance tests c, d, e |
8 |
1 |
8 |
0 |
0 |
0 |
0 |
$0 |
|
|
| b. Review initial performance test reports, performance guarantees, engineering |
4 |
1 |
4 |
0 |
0 |
0 |
0 |
$0 |
|
|
| c. Enter and update information into agency recordkeeping system |
1 |
1 |
1 |
0 |
0 |
0 |
0 |
$0 |
|
|
| 3. Excess emissions – enforcement activities f |
N/A |
|
|
|
|
|
|
|
|
|
| 4. Notification requirements |
|
|
|
|
|
|
|
|
|
|
| a. Review initial notification that existing facilities are subject to the standard c, g |
1 |
1 |
1 |
0 |
0 |
0 |
0 |
$0 |
|
|
| b. Notifications for new area sources h |
|
|
|
|
|
|
|
|
|
|
| (1) Review notification of intent to construct/reconstruct |
4 |
1 |
4 |
0 |
0 |
0 |
0 |
$0 |
|
|
| (2) Review notification of commencement of construction/reconstruction |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
|
|
| (3) Review notification of startup |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
|
|
| c. Review request for compliance extension i |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
|
|
| d. Review notification of initial performance tests c, d, e |
1 |
1 |
1 |
0 |
0 |
0 |
0 |
$0 |
|
|
| e. Review notification of compliance status c, j |
4 |
1 |
4 |
0 |
0 |
0 |
0 |
$0 |
|
|
| 5. Reporting requirements – review semiannual compliance reports k |
4 |
1 |
4 |
13 |
52 |
2.6 |
5.2 |
$2,721.68 |
|
|
| TOTAL ANNUAL BURDEN and COST (rounded) l |
|
|
|
|
62 |
$2,830 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| Assumptions: |
|
|
|
|
|
|
|
|
|
|
| a. We have assumed that there are approximately 26 respondents subject to the rule, with no new sources expected over the next three-years of this ICR. Facilities subject to the NESHAP rules are located in 13 States. |
|
|
|
|
|
|
|
|
|
|
| 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, 2016 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 this is a one-time only cost. |
|
|
|
|
|
|
|
|
|
|
| d. We assume that EPA technical personnel will observe all performance tests conducted by new sources. |
|
|
|
|
|
|
|
|
|
|
| e. We have assumed that not emission tests will need to be performed. Facilities will utilize existing performance tests, performance guarantees, or engineering calculations to demonstrate initial compliance |
|
|
|
|
|
|
|
|
|
|
| f. We have assumed that there would be no enforcement activities for the 3-year period covered by this ICR. |
|
|
|
|
|
|
|
|
|
|
| g. We assume that existing area source facilities must submit notification that they are subject to and the standard within 120 days of the effective date of the final rule. |
|
|
|
|
|
|
|
|
|
|
| h There are no new sources expected. |
|
|
|
|
|
|
|
|
|
|
| i We have assumed that the compliance extensions will not be necessary. |
|
|
|
|
|
|
|
|
|
|
| j Assume that EPA technical personnel will review all of the initial compliance status notifications for new sources. |
|
|
|
|
|
|
|
|
|
|
| k We assume that EPA technical personnel will review 25 percent of the semiannual compliance reports for 26 sources, Number of occurrence = (26 x2 reports) x25% = 13 reports. |
|
|
|
|
|
|
|
|
|
|
| l Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
|
|
|
|
|
|
|
|
|
|