| Table 1: Annual Respondent Burden and Cost - NESHAP for Nine Metal Fabrication and Finishing Area Sources (40 CFR Part 63, Subpart XXXXXX) (Renewal) |
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(A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
(H) |
| Burden Item |
Person-hours per occurrence |
No. of occurrences per respondent per year |
Person-hours per respondent per year (C=AxB) |
Respondents per year a |
Technical person-hours per year (E=CxD) |
Managerial person-hours per year (E x 0.05) |
Clerical person-hours per year (E x 0.10) |
Total Cost, $ b |
| 1. Applications |
N/A |
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| 2. Surveys and Studies |
N/A |
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| 3. Acquisition, Installation, and Utilization of Technology and Systems |
N/A |
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| 4. Reporting Requirements |
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| A. Familiarize with regulatory requirements d |
0.5 |
1 |
0.5 |
5,800 |
2,900 |
145 |
290 |
$379,876.80 |
| B. Required activities |
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| Initial notification c |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
| Notification of compliance status c, e |
4 |
1 |
4 |
0 |
0 |
0 |
0 |
$0 |
| Annual compliance certification f |
2 |
1 |
2 |
5,800 |
11,600 |
580 |
1,160 |
$1,519,507.20 |
| Report of exceedences g |
2 |
1 |
2 |
290 |
580 |
29 |
58 |
$75,975.36 |
| C. Create information |
See 4B |
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| D. Gather existing information |
See 4B |
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| E. Write report |
See 4B |
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| Subtotal for Reporting Requirements |
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17,342 |
$1,975,359.36 |
| 5. Recordkeeping Requirements |
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| A. Familiarize with regulatory requirements |
See 4A |
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| B. Plan activities |
See 5E |
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| C. Implement activities |
See 5E |
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| D. Develop record system |
See 5E |
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| E. Time to enter information |
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| Records of all information required by standards h |
0.25 |
12 |
3 |
5,800 |
17,400 |
870 |
1740 |
$2,279,260.80 |
| F. Time to train personnel |
N/A |
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| G. Time to adjust existing ways to comply with previously applicable requirements |
N/A |
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| H. Time to transmit or disclose information i |
0.25 |
1 |
0.25 |
5,800 |
1,450 |
72.5 |
145 |
$189,938.40 |
| I. Time for audits |
N/A |
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| Subtotal for Recordkeeping Requirement |
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|
|
|
21,678 |
$2,469,199.20 |
| TOTAL LABOR BURDEN AND COST (rounded)j |
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|
|
39,000 |
$4,440,000 |
| TOTAL CAPITAL & O&M COST (rounded) j |
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|
$0 |
| GRAND TOTAL (rounded) j |
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$4,440,000 |
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| Assumptions: |
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6 |
hr per resp |
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| a There are an estimated 5,800 existing metal fabrication and finishing facilities subject to the rule with no new facilities expected. |
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| b This ICR uses the following labor rates: $147.40 for managerial labor, $117.92 for technical labor, and $57.02 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2018, “Table 2. Civilian Workers, by occupational and industry group.” 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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| c One-time notification. |
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| d We have assumed that each respondent will each take 0.5 hours to familiarize with regulatory requirements. |
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| e We have assumed that each respondent will take four hours to complete the notification of compliance status task. |
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| f We have assumed that each respondent will take two hours once per year to complete the task. |
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| g Percentage of respondents with exceedances is assumed to be 5%. |
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| h We have assumed that each respondent will take 0.25 hours once per month to record information that are required by the standards. |
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| i We have assumed that each respondent will take 0.25 hours once per year to transmit or disclose information. |
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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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| Table 2: Average Annual EPA Burden and Cost - NESHAP for Nine Metal Fabrication and Finishing Area Sources (40 CFR Part 63, Subpart XXXXXX) (Renewal) |
| Activity |
(A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
(H) |
|
Person-hours per occurrence |
No. of occurrences per respondent per year |
Person-hours per respondent (C=AxB) |
Respondents per year a |
Technical person-hours (E=CxD) |
Managerial person-hours (Ex0.05) |
Clerical person-hours (Ex0.1) |
Cost, $b |
| Report Review: |
|
| Initial Notification c |
1 |
1 |
1 |
0 |
0 |
0 |
0 |
$0 |
| Notification of compliance status c |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
| Annual Certification/ Compliance Report d |
2 |
1 |
2 |
5,800 |
11,600 |
580 |
1,160 |
$634,212.60 |
| Report of exceedence d,e |
2 |
1 |
2 |
290 |
580 |
29 |
58 |
$31,710.63 |
| TOTAL (rounded)f |
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14,000 |
$666,000 |
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| Assumptions: |
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| a There are an estimated 5,800 existing metal fabrication and finishing facilities subject to the rule with no new facilities expected. |
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| b This ICR uses the following average hourly labor rates: For managerial $65.71 (GS-13, Step 5, $41.07 + 60%), $48.75 (GS-12, Step 1, $30.47 x 1.6) for technical, and $26.38 (GS-6, Step 3, $16.49 x 1.6) for clerical. These rates are from the Office of Personnel Management (OPM), 2018 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. |
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| c One-time notification. |
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| d We have assumed two hours once per year to review reports. |
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| e Percentage of respondents with exceedances is assumed to be 5%. |
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| f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
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