Table 1: Annual Respondent Burden and Cost – NESHAP for Miscellaneous Metal Parts and Products (40 CFR Part 63, Subpart MMMM) (Renewal) |
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117.92 |
147.4 |
57.02 |
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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 yeara |
Technical person- hours per year (E=CxD) |
Management person hours per year (Ex0.05) |
Clerical person hours per year (Ex0.1) |
Cost, $ b |
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1. Familiarization with rule requirements |
4 |
1 |
4 |
390 |
1560 |
78 |
156 |
$204,348 |
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2. Plan activities |
8 |
1 |
8 |
0 |
0 |
0 |
0 |
$0 |
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3. Training |
8 |
1 |
8 |
0 |
0 |
0 |
0 |
$0 |
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4. Create, test, and research and development |
0 |
1 |
0 |
0 |
0 |
0 |
0 |
$0 |
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5. Gather information and monitor |
18 |
12 |
216 |
386 |
83376 |
4168.8 |
8337.6 |
$10,921,589 |
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5.1 Gather information and monitor Magnet wire facilities c |
36 |
12 |
432 |
4 |
1728 |
86.4 |
172.8 |
$226,354 |
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6. Process/Compile and Review |
12 |
12 |
144 |
386 |
55584 |
2779.2 |
5558.4 |
$7,281,059 |
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6.1 Process/Compile and Review - Magnet wire facilities c |
24 |
12 |
288 |
4 |
1152 |
57.6 |
115.2 |
$150,903 |
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7. Semiannual Reports d |
8 |
2 |
16 |
390 |
6240 |
312 |
624 |
$817,390 |
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Subtotal for Reporting Requirements |
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172,086 |
$19,601,643 |
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Recordkeeping requirements |
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8. Record/disclose information e |
4 |
2 |
8 |
390 |
3120 |
156 |
312 |
$408,695 |
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9. Store/File information e |
4 |
2 |
8 |
390 |
3120 |
156 |
312 |
$408,695 |
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10. LDAR reporting and recordkeeping |
0 |
0 |
0 |
0 |
0 |
0 |
0 |
$0 |
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Subtotal for Recordkeeping Requirements |
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7,176 |
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$817,390 |
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TOTAL LABOR BURDEN AND COST (rounded) |
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179,000 |
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$20,400,000 |
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Total Capital/O&M Costs (rounded) |
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$240,000 |
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Grand Total (rounded) |
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$20,600,000 |
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229 |
hr/response |
Assumptions: |
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a We have assumed that there are approximately 390 existing sources currently subject to this rule, with no additional new or reconstructed sources becoming subject to the rule over the next three years of this ICR. |
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b This ICR uses the following labor rates: $147.40 per hour for Executive, Administrative, and Managerial labor; $117.92 per hour for Technical labor, and $57.02 per hour 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 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 assumed that the four magnet wire facilities on average incorporate a higher number of processes that’s typical for the industry. The burden of gathering information, monitoring, and processing compiling, and reviewing has been estimated based on comments received from NEMA. |
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d We have assumed that each respondent will take eight hours twice per year to complete the semiannual reports. |
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e We have assumed that each respondent will take four hours twice per year to complete the task. |
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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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Table 2: Average Annual EPA Burden and Cost – NESHAP for Miscellaneous Metal Parts and Products (40 CFR Part 63, Subpart MMMM) (Renewal) |
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48.75 |
65.71 |
26.38 |
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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 (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) Cost, $ b |
1. Initial performance and test |
N/A |
0 |
0 |
0 |
0 |
0 |
0 |
$0 |
2. Repeat performance test |
N/A |
0 |
0 |
0 |
0 |
0 |
0 |
$0 |
3. Report review |
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a) Initial notification |
8 |
0 |
0 |
0 |
0 |
0 |
0 |
$0 |
b) Notification of performance test |
N/A |
0 |
0 |
0 |
0 |
0 |
0 |
$0 |
c) Notification of compliance status |
12 |
0 |
0 |
0 |
0 |
0 |
0 |
$0 |
d) Semiannual report c |
12 |
2 |
24 |
390 |
9360 |
468 |
936 |
$511,743.96 |
TOTAL ANNUAL BURDEN and COSTS (rounded) |
11,000 |
$512,000 |
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Assumptions: |
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a We have assumed that there are approximately 390 existing sources currently subject to this rule, with no additional new or reconstructed sources becoming subject to the rule over the next three years of this ICR. |
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b This cost is based on the following labor rates: $65.71 for Managerial (GS-13, Step 5, $41.07 + 60%), $48.75 for Technical (GS-12, Step 1, $30.47+ 60%), and $26.38 Clerical (GS-6, Step 3, $16.49+ 60%). 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. |
c We have assumed that each respondent will take 12 hours twice a year to complete semiannual report. |
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d Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
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