|
|
|
|
|
108.28 |
144.33 |
53.34 |
|
|
|
|
|
|
| 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) Total Cost per year b |
|
|
|
|
|
| 1. Applications |
N/A |
|
|
|
|
|
|
|
|
|
|
|
|
| 2. Survey and Studies |
N/A |
|
|
|
|
|
|
|
|
|
|
|
|
| 3. Reporting requirements |
|
|
|
|
|
|
|
|
|
|
|
|
|
| A. Familiarize with Regulatory Requirements c |
1 |
1 |
1 |
149 |
149 |
7.45 |
14.9 |
$18,003.74 |
|
|
|
|
|
| B. Required activities |
|
|
|
|
|
|
|
|
|
|
|
|
|
| Performance Tests |
|
|
|
|
|
|
|
|
|
|
|
|
|
| a. Relative Accuracy Test Audit d |
146 |
2 |
292 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
|
|
| b. CEMS audits (RAA or CGA) e |
160 |
3 |
480 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
|
|
| C. Create information |
See 3B |
|
|
|
|
|
|
|
|
|
|
|
|
| D. Gather existing information |
See 3B |
|
|
|
|
|
|
|
|
|
|
|
|
| E. Write Reports |
|
|
|
|
|
|
|
|
|
|
|
|
|
| i. Notification of construction /reconstruction f |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
|
|
| ii Notification of performance test f |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
|
|
| iii. Report of performance test f |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
|
|
| iv. Semiannual emission reports g |
2 |
2 |
4 |
149 |
596 |
29.8 |
59.6 |
$72,014.98 |
|
|
|
|
|
| Subtotal for Reporting Requirements |
|
|
|
|
857 |
$90,018.72 |
|
|
|
|
|
| 4. Recordkeeping requirements |
|
|
|
|
|
|
|
|
|
|
|
|
|
| A. Familiarize with Regulatory Requirements |
See 3A |
|
|
|
|
|
|
|
|
|
|
|
|
| B. Plan activities |
See 3A |
|
|
|
|
|
|
|
|
|
|
|
|
| C. Implement Activities |
See 3B |
|
|
|
|
|
|
|
|
|
|
|
|
| D. Develop record system |
N/A |
|
|
|
|
|
|
|
|
|
|
|
|
| E. Time to enter information |
|
|
|
|
|
|
|
|
|
|
|
|
|
| Records of Operating Parameters h |
0.25 |
350 |
87.5 |
149 |
13,038 |
651.875 |
1,303.8 |
$1,575,327.64 |
|
|
|
|
|
| F. Time to train personnel |
N/A |
|
|
|
|
|
|
|
|
|
|
|
|
| G. Time for audits |
N/A |
|
|
|
|
|
|
|
|
O and M |
|
|
|
| Subtotal for Recordkeeping Requirements |
|
|
|
|
14,993 |
$1,575,327.64 |
|
714,306 |
|
|
|
| TOTAL LABOR BURDEN AND COST (rounded)i |
|
|
|
|
15,800 |
$1,670,000 |
|
$2,384,306 |
|
|
1,665,346 |
| TOTAL CAPITAL AND O&M COST (rounded)i |
|
|
|
|
|
|
|
$826,000 |
|
|
|
|
|
| GRAND TOTAL (rounded)i |
|
|
|
|
|
|
|
$2,500,000 |
|
|
|
|
|
|
|
|
|
|
|
53 |
hr per resp |
|
|
|
|
|
|
| Assumptions: |
|
|
|
|
|
|
|
|
|
|
|
|
|
| a We have assumed that there are approximately 149 respondents, with no additional new, modified or reconstructed sources becoming subject to NSPS Subpart J over the next three years since any of these events would trigger Subpart Ja applicability. In addition, we have assumed that there is an average one affected facility subject to Subpart J at each petroleum refinery plant. |
|
|
|
|
| b 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 groups. 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 We have assumed each respondent will have to familiarize with the regulatory requirements each year. This is estimated to take one hour. |
|
|
|
|
|
|
|
|
|
|
|
|
|
| d We have assumed that the CEMS accuracy assessment (i.e., relative acccuracy test or RATA) are conducted twice a year and take 146 hours per response. It is assumed that the RATA are typically conducted at the same time as the CGA to save costs. However, all respondents are estimated to comply with the CEMS requirements of 40 CFR Part 60, Subpart Ja and therefore there is no burden associated with this requirement under Subpart J. |
|
|
|
|
| e We have assumed that CEMS audits (Relative Accuracy Audits or Cylinder Gas Audits) are conducted three times per year (Appendix F of Part 60 allows for 3 of 4 quarters, but no more than three quarters in succession) and will take 160 hours per occurance. We have assumed that each respondent has at least one monitor for each parameter requiring monitoring under the standards. However, all respondents are estimated to comply with the CEMS requirements of 40 CFR Part 60, Subpart Ja and therefore there is no burden associated with this requirement under Subpart J. |
|
|
|
|
| f One-time requirement. Not applicable during this year. |
|
|
|
|
|
|
|
|
|
|
|
|
|
| g We have assumed that it will take two hours for each respondent to write semiannual emissions reports twice per year. |
|
|
|
|
|
|
|
|
|
|
|
|
|
| h We have assumed that each respondent will take 0.25 hours per day, and an estimated operational schedule of 350 days per year to enter records of operating parameters. |
|
|
|
|
|
|
|
|
|
|
|
|
|
| i Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
48.08 |
64.8 |
26.02 |
|
|
|
| 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 causing increase in total cost |
| 1. Review reports |
|
|
|
|
|
|
|
|
|
|
| a. Notification of construction/reconstruction c |
0.5 |
1 |
0.5 |
0 |
0 |
0 |
0 |
$0 |
|
|
| b. Notification of performance test d |
0.5 |
1 |
0.5 |
0 |
0 |
0 |
0 |
$0 |
|
|
| c. Semiannual emission reports e |
1.5 |
2 |
3 |
149 |
447 |
22.35 |
44.7 |
$24,103.13 |
|
|
| TOTAL ANNUAL BURDEN AND COST (rounded)f |
|
|
|
|
514 |
$24,100 |
|
|
|
|
|
|
|
|
|
|
|
|
|
| Assumptions: |
|
|
|
|
|
|
|
|
|
|
| a We have assumed that there are approximately 149 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three years. In addition, we have assumed that there is an average one affected facility subject to Subpart J at each petroleum refinery plant. |
|
|
|
|
| b This cost is based on the following hourly labor rates times a 1.6 benefits multiplication factor to account for government overhead expenses: $64.80 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. |
|
|
| c We have assumed that it will take 0.5 hours once a year to review report from new sources; however there are no new sources estimated. |
|
|
|
|
|
|
|
|
|
|
| d We have assumed that it will take 0.5 hours once a year to review performance test report from new sources; however there are no new sources estimated. |
|
|
|
|
|
|
|
|
|
|
| e We have assumed that it will take 1.5 hours, twice per year, to review the excess emission reports. |
|
|
|
|
|
|
|
|
|
|
| f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
|
|
|
|
|
|
|
|
|
|