|
|
|
|
|
106.45 |
138.43 |
52.77 |
|
|
updates: |
|
| 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 (Ex0.1) |
(H) Total Cost Per year b |
|
updated labor rates |
|
| 1. Applications |
N/A |
|
|
|
| 2. Survey and Studies |
N/A |
|
|
|
| 3. Reporting Requirements |
|
|
|
|
| A. Familiarization with the regulatory requirements |
See 3B |
|
|
|
| B. Required Activities |
|
|
|
|
| New Sources |
|
|
|
|
| Initial performance test c |
20.87 |
1 |
20.87 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| Repeat performance test d |
20.87 |
1 |
20.87 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| New and Existing Sources |
|
|
|
|
| Monitoring of emissions and operations |
See 4E |
|
|
|
| C. Create information |
See 3B |
|
|
|
| D. Gather existing information |
See 3E |
|
|
|
| E. Write Report |
|
|
|
|
| New Sources |
|
|
|
|
| Notification of construction/reconstruction/modification |
1.74 |
1 |
1.74 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| Notification of initial startup |
1.74 |
1 |
1.74 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| Notification of CMS demonstration |
1.74 |
1 |
1.74 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| Notification of initial performance test |
1.74 |
1 |
1.74 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| Report of performance test |
See 3B |
|
|
|
| New and Existing Sources |
|
|
|
|
| Semiannual reports e |
13.91 |
2 |
27.82 |
13 |
361.66 |
18.08 |
36.17 |
$42,910.42 |
|
|
|
| Subtotal for Reporting Requirements |
|
|
|
|
416 |
$42,910.42 |
|
|
|
| 4. Recordkeeping requirements |
|
|
|
|
| A. Familiarization with the regulatory requirements |
See 3A |
|
|
|
| B. Plan activities |
See 4E |
|
|
|
| C. Implement Activities |
See 4E |
|
|
|
| D. Develop record system |
N/A |
|
|
|
| E. Time to enter information |
|
|
|
|
| Records monitoring of emissions and operations f |
0.64 |
365 |
233.6 |
13 |
3,036.8 |
151.84 |
303.68 |
$360,311.76 |
|
|
|
| Records of startups, shutdowns, malfunctions, etc. g |
1.3 |
1 |
1.3 |
52 |
67.6 |
3.38 |
6.76 |
$8,020.64 |
|
|
|
| F. Train Personnel |
N/A |
|
|
|
| G. Audits |
N/A |
|
|
|
| Subtotal for Recordkeeping Requirements |
|
|
|
|
3,570 |
$368,332.40 |
|
decrease in hours - mathmatical error |
|
| TOTAL LABOR BURDEN AND COST (rounded) h |
|
|
|
|
3,990 |
$411,000 |
|
61 |
hr/resp |
| Capital and O&M Cost (see Section 6(b)(iii)): h |
|
|
|
|
|
|
|
$11,700 |
|
|
|
| TOTAL COST: h |
|
|
|
|
|
|
|
$423,000 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| Assumptions: |
|
|
|
|
|
|
|
|
|
|
|
| a We have assumed that there are approximately 52 sources currently subject to NSPS, subpart KK. We have assumed that there will be no new sources over the period of this ICR. Therefore, the average number of respondents per year is estimated to be 52. |
|
|
|
|
|
|
|
|
|
|
|
| b This ICR uses the following labor rates: $138.43 per hour for Executive, Administrative, and Managerial labor; $106.45 per hour for Technical labor, and $52.77 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2015, “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. |
|
|
|
|
|
|
|
|
|
|
|
| c All sources are required to use Method 9 for opacity observations, except for lead oxide manufacturing facilities. All respondents would have to perform Method 12 to calculate the lead concentration and the volumetric flow rate of the effluent gases. It requires at least three runs of 60 minutes and 0.85 dscm. |
|
|
|
|
|
|
|
|
|
|
|
| d We have assumed that 20 percent of initial performance tests must be repeated due to failure. |
|
|
|
|
|
|
|
|
|
|
|
| e Semiannual reports are required by this rule for those sources that have to install continuous monitoring systems (e.g., pressure drop monitors across the scrubbing systems). We have assumed that 25% of the sources (i.e., 13 sources) have scrubbing systems. |
|
|
|
|
|
|
|
|
|
|
|
| f Monitoring of emissions and operations requirements includes pressure drop measurements across the scrubbing system at least every 15 minutes, if applicable. We have assumed that 25% of the sources (i.e., 13 sources) have scrubbing systems. |
|
|
|
|
|
|
|
|
|
|
|
| g Monitoring of emissions and operations requirements includes the time it takes to familiarize with the regulatory requirements. |
|
|
|
|
|
|
|
|
|
|
|
| h Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.” |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
47.62 |
64.16 |
25.76 |
|
|
updates: |
| 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 |
|
updated labor rates |
| New Sources |
|
|
|
| Notification of construction/reconstruction |
1.74 |
1 |
1.74 |
0 |
0 |
0 |
0 |
$0 |
|
|
| Notification of initial startup |
0.87 |
1 |
0.87 |
0 |
0 |
0 |
0 |
$0 |
|
|
| Notification of CMS demonstration |
0.87 |
1 |
0.87 |
0 |
0 |
0 |
0 |
$0 |
|
|
| Notification of Initial Performance Test |
0.43 |
1.2 |
0.52 |
0 |
0 |
0 |
0 |
$0 |
|
|
| Initial Performance Test |
20.87 |
1 |
20.87 |
0 |
0 |
0 |
0 |
$0 |
|
|
| Repeat of Performance Test c |
20.87 |
0.2 |
4.17 |
0 |
0 |
0 |
0 |
$0 |
|
|
| Review Performance Test results c |
6.96 |
1.2 |
8.35 |
0 |
0 |
0 |
0 |
$0 |
|
|
| New and Existing Sources |
|
|
|
| Review of Semi-annual Reports d |
2 |
1 |
2 |
13 |
26 |
1.3 |
2.6 |
$1,388.50 |
|
decrease in hours - mathmatical error |
| TOTAL ANNUAL BURDEN AND COST (rounded) e |
|
|
|
|
30 |
$1,390 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| Assumptions: |
|
|
|
|
|
|
|
|
|
|
| a We have assumed that there are approximately eighty-nine respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three years. Within those eighty-nine existing sources, only seventy-six are subject to the emission limits in the standard. The remaining thirteen respondents are permitted as synthetic minors and, therefore, are not subject to the emission limits in the standard. |
|
|
|
|
|
|
|
|
|
|
| b This cost is based on the following hourly labor rates times a 1.6 benefits multiplication factor to account for government overhead expenses: $64.16 for Managerial, $47.62 for Technical and $25.76 for Clerical. These rates are from the Office of Personnel Management (OPM) “2016 General Schedule” which excludes locality rates of pay. |
|
|
|
|
|
|
|
|
|
|
| c We have assumed that 20 percent of initial performance tests is typically repeated due to failure. |
|
|
|
|
|
|
|
|
|
|
| d We have assumed that 25 percent of the 52 existing sources (i.e., 13 sources) have scrubber systems and are therefore, required to install and maintain a monitor to measure and record pressure drop across the scrubbing system, and submit semi-annual reports. |
|
|
|
|
|
|
|
|
|
|
| e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.” |
|
|
|
|
|
|
|
|
|
|