|
Bureau of Labor Statistics, 2019 |
117.92 |
147.4 |
57.02 |
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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 yeara |
(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 |
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| 1. Applications |
N/A |
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| 2. Surveys and studies |
N/A |
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| 3. Reporting requirements |
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| a. Familiarization with the regulartory requirement |
1 |
1 |
1 |
202 |
202 |
10.10 |
20.20 |
$26,460.38 |
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| b. Required activities |
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| i. Initial performance test – process vents c |
480 |
1 |
480 |
1 |
480 |
24 |
48 |
$62,876.16 |
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| ii. Initial performance test – wastewater c |
160 |
1 |
160 |
1 |
160 |
8 |
16 |
$20,958.72 |
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| iii. Initial CMS performance evaluation d |
10 |
1 |
10 |
0 |
0 |
0 |
0 |
$0 |
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| iv. Repeat performance test |
20 |
1 |
20 |
1 |
20 |
1 |
2 |
$2,619.84 |
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| c. Create information |
See 3E |
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| d. Gather existing information |
See 3E |
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| e. Write report |
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| i. Notification of construction/reconstruction |
2 |
1 |
2 |
1 |
2 |
0.10 |
0.20 |
$261.98 |
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| ii. Notification of actual startup |
2 |
1 |
2 |
1 |
2 |
0.10 |
0.20 |
$261.98 |
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| iii. Initial notification |
2 |
1 |
2 |
1 |
2 |
0.10 |
0.20 |
$261.98 |
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| iv. Emissions averaging plan e |
40 |
1 |
40 |
0 |
0 |
0 |
0 |
$0 |
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| v. Pre-compliance report f |
40 |
1 |
40 |
1 |
20 |
1 |
2 |
$2,619.84 |
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| vi. Performance test notification g |
2 |
1 |
2 |
1 |
2 |
0.10 |
0.20 |
$261.98 |
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| vii. Notification of initial CMS performance evaluation |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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| viii. Notification of compliance status |
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| a. With performance test g |
80 |
1 |
80 |
1 |
80 |
4 |
8 |
$10,479.36 |
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| b. Without performance test h |
120 |
1 |
120 |
0 |
0 |
0 |
0 |
$0 |
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| ix. Notification of physical/operational change i |
8 |
1 |
8 |
20.2 |
161.6 |
8.08 |
16.16 |
$21,168.31 |
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| x. Semiannual summary report |
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| a. No deviations j |
8 |
2 |
16 |
181.8 |
2,908.8 |
145.44 |
290.88 |
$381,029.53 |
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| b. Deviations j |
24 |
2 |
48 |
20.2 |
969.6 |
48.48 |
96.96 |
$127,009.84 |
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| c. SS&M report k |
8 |
2 |
16 |
202 |
3,232 |
161.60 |
323.20 |
$423,366.14 |
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| d. LDAR report l |
404 |
2 |
808 |
202 |
163,216 |
8,160.80 |
16,321.60 |
$21,379,990.27 |
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| e. Emission averaging report m |
20 |
2 |
40 |
20.1 |
804 |
40.20 |
80.40 |
$105,317.57 |
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| Subtotal for Reporting Requirements |
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198,101 |
$22,564,943.90 |
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| 4 Recordkeeping requirements |
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| a. Familiarize with the regulatory requirements |
See 3E |
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| b. Plan activities |
N/A |
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| c. Implement activities |
N/A |
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| d. Develop record system n |
40 |
1 |
40 |
1 |
40 |
2 |
4 |
$5,239.68 |
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| e. Develop SS&M plan o |
100 |
1 |
100 |
1 |
100 |
5 |
10 |
$13,099.20 |
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| f. Develop QA/QC plan for CMS p |
40 |
1 |
40 |
0 |
0 |
0 |
0 |
$0 |
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| g. Time to train personnel q |
40 |
1 |
40 |
1 |
40 |
2 |
4 |
$5,239.68 |
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| h. Time to retrain/refresh personnel r |
16 |
1 |
16 |
201 |
3,216 |
160.80 |
321.60 |
$421,270.27 |
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| i. Time to enter information |
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| i. Records of SS&M |
1.5 |
52 |
78 |
202 |
15,756 |
787.80 |
1,575.60 |
$2,063,909.95 |
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| ii. Records of CMS data s |
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Annual number of respondents (total) |
202 |
| a. Record of continuously monitored parameters |
1 |
365 |
365 |
202 |
73,730 |
3,686.50 |
7,373.00 |
$9,658,040.16 |
|
Annual avg number of existing respondents |
201 |
| b. Compile data |
24 |
2 |
48 |
202 |
9,696 |
484.80 |
969.60 |
$1,270,098.43 |
|
Annual avg number of new respondents |
1 |
| c. Enter/verify information for semiannual report |
16 |
2 |
32 |
202 |
6,464 |
323.20 |
646.40 |
$846,732.29 |
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| j. Calibration of CMS t |
16 |
1 |
16 |
202 |
3,232 |
161.60 |
323.20 |
$423,366.14 |
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| Subtotal for Recordkeeping Requirements |
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129,115 |
$14,706,996 |
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| Total Annual Labor Burden and Costs (rounded) u |
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|
327,000 |
$37,300,000 |
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| Capital and O&M Cost (rounded): u |
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|
$4,310,000 |
|
255 |
hr per resp |
| Grand Total (rounded): u |
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$41,600,000 |
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| a We have assumed that there are 201 existing facilities subject to the rule, and that one new major source per year will become subject. Therefore, the average number of respondents that are subject to this rule is 202. |
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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 This will occur only in the first year after a facility becomes subject to the rule. |
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| d Person-hours per occurrence are based on the performance specification costs to certify CMS ($500) divided by the composite hourly labor rate. No performance evaluations are required for the parameter monitoring systems included in the rule. Assumes no facilities will use the alternative standard, which required CEMS and performance evaluations. |
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| e We have assumed that 10 percent of existing facilities will comply with emissions averaging requirements and have previously submitted an averaging plan; new facilities are not allowed to use emissions averaging. |
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| f Assumes 1 new facility will submit a pre-compliance report. |
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| g We have assumed that 1 new facility will comply by conducting a performance test(s). The notification of compliance status includes the report of the performance test(s). |
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| h We have assumed that no new facilities will comply by submitting engineering calculations, design calculations, etc. with no performance tests. The notification of compliance status includes those calculations. |
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| i We have assumed that 10 percent of facilities will implement process changes |
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| j We have assumed that 90 percent of facilities will have no deviations, only 10 percent will have deviations. |
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| k We assume that all facilities will report actions taken during startup, shutdown, or malfunction that are consistent with the SS&M plan. |
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| l Assumes 404 hours for completion of the LDAR report. |
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| m We have assumed that 10 percent of existing facilities will comply with emissions averaging requirements; new facilities are not allowed to use emissions averaging. |
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| n We have assumed that it will take 40 hours for each respondent to develop a record system for recording parameter monitoring information. |
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| o We have assumed that it will take 80 hours for each respondent to draft the startup, shutdown, and malfunction plan and another 20 hours of review/revisions, for a total of 100 hours. |
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| p We have assumed that it will take 40 hours to develop and review the QA/QC plan for the CMS. No QA/QC plan is required for the parameter monitoring systems included in the rule. We have assumed that no facility will use the alternative standard, which requires CEMS and QA/QC plans. |
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| q We have assumed that it will take 40 hours to train personnel. |
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| r We have assumed it will take 20 days (16 hours) to provide refresher training for personnel. |
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| s The record of continuously monitored parameters includes: process vent, storage tank, and wastewater monitoring and inspections. |
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| t We have assumed that calibration of CMS will require 8 hours per year for each monitor. We are assuming a total of 2 CMS for each facility, for a total requirement of 16 hours per year per facility. |
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| uTotals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
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2015 General Schedule |
48.75 |
65.71 |
26.38 |
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| Activity |
(A) EPA person hours per occurrence |
(B) No. of occurrences per plant per year |
(C) EPA person hours per respondent per year (C=AxB) |
(D) Plants per yeara |
(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 |
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| 1. Review notification of construction/reconstruction |
2 |
1 |
2 |
1 |
2 |
0.10 |
0.20 |
$109.35 |
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| 2. Review notification of actual startup |
1 |
1 |
1 |
1 |
1 |
0.05 |
0.10 |
$54.67 |
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| 3. Review initial notification |
2 |
1 |
2 |
1 |
2 |
0.10 |
0.20 |
$109.35 |
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| 4. Review emissions averaging plan c |
20 |
1 |
20 |
0 |
0 |
0 |
0 |
$0 |
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| 5. Review pre-compliance report d |
4 |
1 |
4 |
1 |
4 |
0.20 |
0.40 |
$218.69 |
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| 6. Review notification of initial performance test |
2 |
1 |
2 |
1 |
2 |
0.10 |
0.20 |
$109.35 |
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| 7. Review notification of initial CMS demonstration |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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| 8. Review notification of compliance status report |
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| i. With performance test e |
40 |
1 |
40 |
1 |
40 |
2 |
4 |
$2,186.94 |
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| ii. Without performance test f |
40 |
1 |
40 |
0 |
0 |
0 |
0 |
$0 |
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| 9. Review notification physical/operational changeg |
8 |
1 |
8 |
20.2 |
161.6 |
8.08 |
16.16 |
$8,835.24 |
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| 10. Review semiannual summary report |
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| i. No deviations h |
2 |
2 |
4 |
181.8 |
727.2 |
36.36 |
72.72 |
$39,758.57 |
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Annual avg number of respondents (total) |
202 |
| ii. Deviations h |
8 |
2 |
16 |
20.2 |
323.2 |
16.16 |
32.32 |
$17,670.48 |
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Annual avg number of existing respondents |
201 |
| iii. SS&M report i |
2 |
2 |
4 |
202 |
808 |
40.40 |
80.80 |
$44,176.19 |
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Annual avg number of new respondents |
1 |
| iv. LDAR report j |
8 |
2 |
16 |
202 |
3,232 |
161.60 |
323.20 |
$176,704.75 |
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| v. Emission averaging report c |
8 |
2 |
16 |
20.1 |
321.6 |
16.08 |
32.16 |
$17,583.00 |
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| Subtotals Labor Burden and cost |
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6,468 |
$307,516.57 |
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| Total Annual Labor Burden and Costs (rounded)k |
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6,500 |
$308,000 |
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| a We have assumed that there are 201 existing facilities subject to the rule, and that one new major source per year will become subject. Therefore, the average number of respondents that are subject to this rule is 202. |
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| b This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: $65.71 (GS-13, Step 5, $41.07 + 60%) for Managerial rate, $48.75 (GS-12, Step 1, $30.47 + 60%) for Technical rate, and $26.38 (GS-6, Step 3, $16.49 + 60%) for Clerical rate. These rates are from the Office of Personnel Management (OPM) “2018 General Schedule” which excludes locality rates of pay. |
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| c We have assumed that 10 percent of existing facilities will comply with emissions averaging requirements and have previously submitted an averaging plan; new facilities are not allowed to use emissions averaging. |
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| d We have assumed one new faclity will submit a pre-compliance report. |
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| e We have assumed that one new facility will comply by conducting a performance test(s). The notification of compliance status includes the report of the performance test(s). |
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| f We have assumed that no new facilities will comply by submitting engineering calculations, design calculations, etc. with no performance tests. The notification of compliance status includes those calculations. |
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| g We have assumed that 10 percent of facilities will implement process changes. |
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| h We have assumed that 90 percent of facilities will have no deviations, 10 percent will have deviations. |
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| i We have assumed that all facilities will report actions taken during startup, shutdown, or malfunction that are consistent with the SS&M plan. |
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| j We have assumed that all facilities will report the specified information for processes subject to the equipment leak standards. |
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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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