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Sep 2016 Labor Rates |
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108.28 |
144.33 |
53.34 |
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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 (A x B) |
(D) Respondents per year a |
(E) Technical person- hours per year (C x D) |
(F) Management person hours per year (E x0.05) |
(G) Clerical person hours per year (E x 0.1) |
(H) Total Cost per year 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. Familiarization with Regulatory Requirements b |
4 |
1 |
4 |
90 |
360 |
18 |
36 |
$43,499 |
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| B. Required activities b |
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| Develop plans for demonstrating compliance b |
80 |
1 |
80 |
1 |
80 |
4 |
8 |
$9,666 |
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# of responses |
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1 |
| Develop SSM plan b, c |
100 |
1 |
100 |
1 |
100 |
5 |
10 |
$12,083 |
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1 |
| C. Create information |
N/A |
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| D. Gather existing information |
See 4E |
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| E. Write Report |
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| Initial notification of intent to construct/reconstruction d |
8 |
1 |
8 |
2 |
16 |
0.8 |
1.6 |
$1,933 |
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2 |
| Application for construction/ reconstruction d |
8 |
1 |
8 |
2 |
16 |
0.8 |
1.6 |
$1,933.29 |
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2 |
| Notification of commencement of construction/reconstruction d |
8 |
1 |
8 |
2 |
16 |
0.8 |
1.6 |
$1,933.29 |
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2 |
| Notification of anticipated startup d |
8 |
1 |
8 |
2 |
16 |
0.8 |
1.6 |
$1,933.29 |
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2 |
| Notification of actual startup d |
8 |
1 |
8 |
2 |
16 |
0.8 |
1.6 |
$1,933.29 |
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2 |
| Notification of compliance status d,e |
24 |
1 |
24 |
2 |
48 |
2.4 |
4.8 |
$5,799.86 |
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2 |
| Annual compliance certification e |
24 |
1 |
24 |
90 |
2,160 |
108 |
216 |
$260,993.88 |
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90 |
| Periodic startup, shutdown, malfunction report f |
24 |
1 |
24 |
5 |
120 |
6 |
12 |
$14,499.66 |
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5 |
| Immediate startup, shutdown malfunction report d, g |
8 |
1 |
8 |
1 |
8 |
0.4 |
0.8 |
$966.64 |
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1 |
| Notification of deviation report d, i |
8 |
1 |
8 |
1 |
8 |
0.4 |
0.8 |
$966.64 |
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1 |
| Subtotal for Reporting Requirements |
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3,409 |
$358,142 |
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Total |
111 |
| 4. Recordkeeping requirements |
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| A. Familiarization with Regulatory Requirements b |
See 3A |
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| B. Develop record system |
N/A |
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| C. Time to enter information |
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| Solvent inventory e, h |
8 |
12 |
96 |
90 |
8,640 |
432 |
864 |
$1,043,975.52 |
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| HAP content of solvent e, h |
8 |
12 |
96 |
90 |
8,640 |
432 |
864 |
$1,043,975.52 |
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| Oilseed inventory e, h |
8 |
12 |
96 |
90 |
8,640 |
432 |
864 |
$1,043,975.52 |
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| D. Record startup, shutdown, malfunction activities j |
12 |
12 |
144 |
1 |
144 |
7.2 |
14.4 |
$17,399.59 |
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| E. Time to train personnel b |
40 |
1 |
40 |
0 |
0 |
0 |
0 |
$0 |
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| F. Time for audits |
N/A |
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| Subtotal for Recordkeeping Requirements |
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29,974 |
$3,149,326 |
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| TOTAL LABOR BURDEN AND COST (rounded)k |
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33,400 |
$3,510,000 |
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| TOTAL CAPITAL AND O&M COST (rounded)k |
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$0 |
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| GRAND TOTAL (rounded)k |
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$3,510,000 |
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301 |
hr / response |
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| Assumptions: |
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| a This ICR uses the following labor rates: $144.03 per hour for Executive, Administrative, and Managerial labor; $108.28 per hour for Technical labor, and $53.34 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2016, 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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| b We have assumed that there are approximately 89 existing sources that are subject to the standard. We have assumed that there will be a growth rate of one new source per year, on average, over the three-year period of this ICR based on input from the affected industry. We assume that each respondent will have to familiarize with the regulatory requirements each year. |
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| c We have assumed that it will take one hundred hours to develop a startup, shutdown, malfunction (SSM) This is a one-time requirement for new sources. |
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| d We have assumed that one existing facility will be reconstructed and one new source will be constructed each year over the next three years. |
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| e We have assumed that there are approximately 90 sources that are subject to the standard and will submit annual compliance certifications and maintain records. The initial compliance status notification does not apply to existing sources as that is a one-time requirement. It is required for new and reconstructed sources. |
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| f We have assumed that five percent of sources will submit a periodic SSM report. |
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| g It is estimated that one source will submit an immediate SSM report. |
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| h We have assumed that it will take eight hours once per month for data to be recorded. |
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| i We have assumed that one source will submit a notification of deviation report each year. |
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| j We have estimated that it will take twelve hours to record startup, shutdown, and malfunction activities. |
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| k Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
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2017 Schedule |
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48.08 |
64.8 |
26.02 |
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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 |
| Report review |
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| Initial notification b |
8 |
1 |
8 |
2 |
16 |
0.8 |
1.6 |
$863 |
| Review approve construction/reconstruction application c |
24 |
1 |
24 |
2 |
48 |
2.4 |
4.8 |
$2,588.26 |
| Notification of construction/reconstruction c |
24 |
1 |
24 |
2 |
48 |
2.4 |
4.8 |
$2,588.26 |
| Notification to begin construction c |
4 |
1 |
4 |
2 |
8 |
0.4 |
0.8 |
$431.38 |
| Notification of anticipated startup c |
4 |
1 |
4 |
2 |
8 |
0.4 |
0.8 |
$431.38 |
| Notification of actual startup c |
4 |
1 |
4 |
2 |
8 |
0.4 |
0.8 |
$431.38 |
| Review of compliance status c,d |
16 |
1 |
16 |
2 |
32 |
1.6 |
3.2 |
$1,725.50 |
| Review of annual compliance certification d |
16 |
1 |
16 |
90 |
1,440 |
72 |
144 |
$77,647.68 |
| Review of periodic startup, shutdown, malfunction reports e |
8 |
1 |
8 |
5 |
40 |
2 |
4 |
$2,156.88 |
| Review of immediate SSM report f, g |
16 |
1 |
16 |
1 |
16 |
0.8 |
1.6 |
$862.75 |
| Review of deviation report h, i |
4 |
1 |
4 |
1 |
4 |
0.2 |
0.4 |
$215.69 |
| Review compliance plans |
40 |
1 |
40 |
0 |
0 |
0 |
0 |
$0 |
| Review SSM plans |
40 |
1 |
40 |
0 |
0 |
0 |
0 |
$0 |
| TOTAL ANNUAL BURDEN AND COST (rounded)j |
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1,920 |
$89,900 |
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| Assumptions: |
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| a This cost is based on the following hourly labor rates times a 1.6 benefits multiplication factor to account for government overhead expenses: $64.80 for Managerial, $48.08 for Technical and $26.02 Clerical. These rates are from the Office of Personnel Management (OPM) "2017 General Schedule" which excludes locality rates of pay. |
| b We have assumed that there will be one new facility per year, on average over the next three years. The initial compliance status notification does not apply to existing sources as that is a one-time requirement. It is required for reconstructed and new sources. |
| c We have assumed that one existing facility will be reconstructed each year over the next three years. |
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| d We have assumed that there are approximately 90 sources that are subject to the standard. |
| e We have assumed that five percent of sources will submit a periodic SSM report. |
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| f It is estimated that one of the sources will submit an immediate SSM report. |
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| g We have assumed that it will take sixteen hours to review an immediate SSM report. |
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| h We have assumed that it will take four hours to review the deviation report. |
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| i We have assumed that one source will submit a notification of deviation report each year. |
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| j Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
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