| Table 1: Annual Respondent Burden and Cost – NSPS for Stationary Source Compression Ignition Internal Combustion Engines (40 CFR Part 60, Subpart IIII) (Renewal) |
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103.97 |
129.93 |
51.79 |
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| Burden item |
(A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
(H) |
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| 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) |
Management person hours per year
(Ex0.05) |
Clerical person hours per year
(Ex0.1) |
Total Cost
Per year b |
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| 1. Applications |
N/A |
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| A. Certification for stationary use |
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| - Certification application c |
44 |
1 |
44 |
35 |
1,540 |
77 |
154 |
$178,094.07 |
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| - Recordkeeping |
4.4 |
1 |
4.4 |
154 |
678 |
33.88 |
67.76 |
$78,361.39 |
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| - Certificate/durability testing d |
168 |
1 |
168 |
35 |
5,880 |
294 |
588 |
$679,995.54 |
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Dwang(8):
This burden item is also in the Capital/Startup vs O&M table. Not sure why one respondent is accounted for in the burden estimate table, but 200 respondents are accounted for in the O&M table….
- Selective enforcement audits |
115 |
1 |
115 |
1 |
115 |
5.75 |
11.5 |
$13,299.23 |
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| - Defect reporting e |
125 |
1 |
125 |
4 |
500 |
25 |
50 |
$57,822.75 |
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| B. Certification for stationary/non-road use |
1 |
1 |
1 |
200 |
200 |
10 |
20 |
$23,129.10 |
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| 2. Surveys and studies |
N/A |
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| 3. Reporting requirements |
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| A. Read and understand rule requirementf |
1 |
1 |
1 |
40 |
40 |
2 |
4 |
$4,625.82 |
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| B. Required activities |
See 3D |
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| C. Gather existing information |
See 3D |
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| D. Write report |
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| Initial notification |
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| >3,000 hp, prime g |
2 |
1 |
2 |
32 |
64 |
3.2 |
6.4 |
$7,401.31 |
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| >10 l/cyl, prime h |
2 |
1 |
2 |
8 |
16 |
0.8 |
1.6 |
$1,850.33 |
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| Pre-2007, not certified, prime, >175 hp |
N/A |
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DWang:
The RICE NESHAP assumes 16 hours/annual report for emergency operation. The required emergency operation annual report contents for this rule and the RICE NESHAP are almost identical, so I assumed the same labor hours.
E. Annual report for emergency stationary CI ICEi |
16 |
1 |
16 |
10,327 |
165,224 |
8,261.2 |
16,522.4 |
$19,107,412.09 |
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| Subtotal for Reporting Requirements |
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200,395 |
$20,151,992 |
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| 4. Recordkeeping requirements |
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| A. Read and understand rule requirement j |
1 |
1 |
1 |
56,204 |
56,204 |
2,810.2 |
5,620.4 |
$6,499,739.68 |
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| B. Train personnel |
N/A |
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| C. Recording CDPF corrective actionk |
1 |
1 |
1 |
20,653 |
20,653 |
1,032.65 |
2,065.3 |
$2,388,426.51 |
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| D. Recording hours in non-emergency operation l |
0.5 |
1 |
0.5 |
206,530 |
103,265 |
5163.25 |
10326.5 |
$11,942,132.56 |
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| Subtotal for Recordkeeping Requirements |
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207,140 |
$20,830,299 |
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| TOTAL LABOR BURDEN AND COST (rounded)m |
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408,000 |
$41,000,000 |
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| Total Capital/O&M Costsm |
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$167,000 |
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| Grand Total (Labor and Capital/O&M Costs)m |
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$41,200,000 |
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38 |
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hr/response |
| Assumptions: |
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| a We have assumed that there are 206,530 sources currently subject to the regulations, and it is estimated that 40 new sources are expected each year over the next three years. |
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| b This ICR uses the following labor rates: $129.93 per hour for Executive, Administrative, and Managerial labor; $103.97 per hour for Technical labor, and $51.79 per hour for Clerical labor. 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. |
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| c We have assumed that it will take 44 hours for all affected facilities to complete the certification application. |
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| d We have assumed that it will take 168 hours for all affected facilities to complete the certificate/durability testing. |
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| e We have assumed that it will take 125 hours for all affected facilities to complete the defect report. |
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| f We have assumed that each of the 40 respondents will take one hour to read instructions. |
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| g We have assumed that 80 percent of the 40 affected facilities are required to write the >3,000 hp, prime report. |
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| h We have assumed that 20 percent of the 40 affected facilities will write the 10 l/cyl prime report. |
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| i We have assumed 16 hours per annual report based on ICR 1975.06 (NESHAP For Stationary Reciprocating Internal Combustion Engines 40 CFR Part 63, Subpart ZZZZ) and that 5% of respondents must submit an annual report. |
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| j We have assumed that on average 56,204 of the 206,530 respondents will read rule instructions each year. |
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| k We have assumed that it will take 10% of respondents 1 hour to keep records of corrective actions taken for CI ICE equipped with diesel particulate filters. |
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| l We have assumed that respondents are required to keep the records for the recording hours in non-emergency operation. |
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| m 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 – NSPS for Stationary Source Compression Ignition Internal Combustion Engines (40 CFR Part 60, Subpart IIII) (Renewal) |
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46.67 |
62.9 |
25.25 |
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| Activity |
(A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
(H) |
| EPA person- hours per occurrence |
No. of occurrences per plant per year |
EPA person- hours per plant per year |
Plants per year a |
Technical person- hours per year |
Management person-hours per year |
Clerical person-hours per year |
Cost, $ b |
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(C=AxB) |
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(E=CxD) |
(Ex0.05) |
(Ex0.1) |
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| Report Review |
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| 1. Initial notification of compliance c |
2 |
1 |
2 |
40 |
80 |
4 |
8 |
$4,187.20 |
| 2. Certification application |
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| A. Certification for stationary use d |
2 |
1 |
2 |
35 |
70 |
3.5 |
7 |
$3,663.80 |
| B. Certification for stationary/non-road use e |
1 |
1 |
1 |
200 |
200 |
10 |
20 |
$10,468.00 |
| TOTAL ANNUAL BURDEN AND COST (rounded)f |
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403 |
$18,300 |
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| Assumptions: |
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| a We have assumed that there are 206,530 sources currently subject to the regulations, and it is estimated that 40 new sources are expected each year over the next three years. |
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| b This cost is based on the following hourly labor rates: $62.90 for Managerial (GS-13, Step 5, $39.31 + 60%), $46.67 for Technical (GS-12, Step 1, $29.17 + 60%) and $25.25 Clerical (GS-6, Step 3, $15.78 + 60%). These rates are from the Office of Personnel Management (OPM) “2014 General Schedule” which excludes locality rates of pay. These rates have been increased by 60 percent to account for the benefit packages available to government employees. |
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Dwang:
I changed "review" to "submit"
c We have assumed that each of the 40 affected facilities would have to submit the initial notification of compliance report. |
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DWang:
Changed from "We have assumed that it will take 2 hours for each respondent to review the certification for stationary use report."
d We have assumed that it will take 2 hours to review the certification for stationary use report for each respondent. |
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DWang:
Changed from: "We have assumed that it will take each of the respondent one hour one time per year to review the certification for stationary/non-road use."
e We have assumed that it will take one hour one time per year to review the certification for stationary/non-road use for each respondent. |
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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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