| Table 1a: Annual Respondent Burden and Cost for Private Facilities – NESHAP for Perchloroethylene Dry Cleaning Facilities (40 CFR Part 63, Subpart M) (Renewal) |
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| Burden Item |
A |
B |
C |
D |
E |
F |
G |
H |
|
|
|
| Hours per occurrence |
Occurrences per respondent per year |
Hours per respondent per year |
Respondents per yeara |
Technical hours per year |
Management hours per year |
Clerical hours per year |
Total cost per year ($)b |
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|
|
|
|
(AxB) |
|
(CxD) |
(Ex0.05) |
(Ex0.10) |
|
|
|
|
| 1. Applications |
N/A |
|
|
|
|
|
|
|
|
Labor Rates: |
| 2. Survey and Studies |
N/A |
|
|
|
|
|
|
|
|
Management |
$147.40 |
| 3. Reporting Requirements |
|
|
|
|
|
|
|
|
|
Technical |
$117.92 |
| A. Familiarization with the regulatory requirements c |
1 |
1 |
1 |
28,013 |
0 |
28,013 |
0 |
$4,129,116 |
|
Clerical |
$57.02 |
| B. Required activities |
N/A |
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|
|
|
|
|
|
|
|
| C. Create Information |
N/A |
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|
|
|
|
|
|
|
| D. Gather existing information |
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|
|
|
|
|
|
|
|
|
| Initial report information |
2 |
1 |
2 |
2,330 |
4,660 |
233 |
466 |
$610,423 |
|
|
|
| Solvent consumption |
1 |
1 |
1 |
2,330 |
2,330 |
116.5 |
233 |
$305,211 |
|
|
|
| Compliance method report d |
1 |
1 |
1 |
1,631 |
1,631 |
81.55 |
163.1 |
$213,648 |
|
|
|
| E. Write Report |
|
|
|
|
|
|
|
|
|
|
|
| Initial notification report |
1 |
1 |
1 |
2,330 |
2,330 |
116.5 |
233 |
$305,211 |
|
|
|
| Compliance method report c, d |
1 |
1 |
1 |
1,631 |
0 |
1,631 |
0 |
$240,409 |
|
|
|
| Solvent consumption report c, e |
0.25 |
1 |
0.25 |
699 |
0 |
174.75 |
0 |
$25,758 |
|
|
|
| Report-exceed consumption cutoff c, f |
1 |
1 |
1 |
117 |
0 |
117 |
0 |
$17,172 |
|
|
|
| Subtotal for Reporting Requirements |
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|
|
|
42,529 |
$5,846,949 |
|
|
|
| 4. Recordkeeping Requirements |
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|
|
|
|
|
|
|
| A. Familiarization with the regulatory requirements |
See 3A |
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|
|
|
|
|
|
|
|
|
| B. Plan activities g |
1 |
1 |
1 |
2,330 |
2,330 |
0 |
0 |
$274,754 |
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|
|
| C. Implement activities |
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|
|
|
|
|
|
|
| Above consumption cutoff: Weekly LDAR g, h, i |
0.75 |
52 |
39 |
19,595 |
764,209 |
0 |
0 |
$90,115,513 |
|
|
|
| Below consumption cutoff: Bi-weekly LDAR g, i, j |
0.75 |
26 |
19.5 |
8,398 |
163,759 |
0 |
0 |
$19,310,467 |
|
|
|
| Major: Monthly enhanced LDAR k, l |
1 |
48 |
48 |
13 |
624 |
31.2 |
62.4 |
$81,739 |
|
|
|
| Major: Weekly Carbon adsorber monitoring l, m |
0.25 |
208 |
52 |
13 |
676 |
33.8 |
67.6 |
$88,551 |
|
|
|
| Area: Monthly enhanced LDAR n, o |
0.75 |
12 |
9 |
20,000 |
180,000 |
9,000 |
18,000 |
$23,578,560 |
|
|
|
| D. Develop record system |
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|
|
|
|
|
|
|
|
| Solvent consumption g |
1 |
1 |
1 |
2,330 |
2,330 |
0 |
0 |
$274,754 |
|
|
|
| Enhanced LDAR g |
1 |
1 |
1 |
2,330 |
2,330 |
0 |
0 |
$274,754 |
|
|
|
| Monitoring records d, g |
1 |
1 |
1 |
1,631 |
1631 |
0 |
0 |
$192,328 |
|
|
|
| Carbon adsorber monitoring records p |
1 |
1 |
1 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| E. Time to enter information |
|
|
|
|
|
|
|
|
|
|
|
| Monthly records of solvent consumption q, r, s |
0.25 |
12 |
3 |
28,013 |
84,039 |
9 |
0 |
$9,911,205 |
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|
| Above consumption cutoff: Records of weekly inspections h, i, s |
0.25 |
52 |
13 |
19,595 |
254,736 |
39 |
0 |
$30,044,253 |
|
|
|
| Below consumption cutoff: Records of bi-weekly inspections g, i, j |
0.25 |
26 |
6.5 |
8,398 |
54,586 |
0 |
0 |
$6,436,822 |
|
|
|
| Major: Enhanced LDAR |
See 4C |
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|
| Major: Carbon adsorber monitoring |
See 4C |
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| Area: Enhanced LDAR |
See 4C |
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| F. Time to Train personnel |
|
|
|
|
|
|
|
|
|
|
|
| Leak detection t, u |
1 |
2 |
2 |
2,330 |
4,660 |
4,660 |
0 |
$1,236,391 |
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|
|
| G. Time for audits |
N/A |
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|
|
|
|
|
|
|
|
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| Subtotal for Recordkeeping Requirements |
|
|
|
|
1,547,814 |
$181,820,091 |
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|
| Total Labor Burden and Cost (rounded) v |
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|
1,590,000 |
$188,000,000 |
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| Total Capital and O&M Cost (rounded) v |
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|
|
$947,000 |
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| Grand TOTAL (rounded) v |
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|
|
$189,000,000 |
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| Assumptions |
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| a We have assumed that there are 28,000 existing area sources and that 2,330 sources will leave the industry and will be replaced by 2,330 new area sources per year over the next three years. We assume that all existing and new area sources are private sector facilities. There are 20 existing major sources and 13 of these sources are private sector facilities. We assume that that no additional major sources will be subject to the NESHAP over the three-year period 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% to account for the benefit packages available to those employed by private industry. |
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| c This task requires management hours only. |
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| d We estimate that 1,631 (70 percent) of the 2,330 new facilities will be above the consumption cutoff and are required to perform this task. |
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| e We estimate that 699 (30 percent) of the 2,330 new facilities will be below the consumption cutoff (will consume less than 140 gallons of PCE per year) and are required to perform this task. |
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| f We estimate that 5 percent of new facilities each year will exceed the cutoff, thus requiring submission of the exceed-consumption cutoff report. |
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| g This task requires only technical employee hours. |
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| h Occurrences are based on weekly inspection, assuming 52 weeks per year. |
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| i We have assumed that of 28,000 area source perchloroethylene dry cleaners, 19,600 (70 percent) will be above the per consumption cutoff, which will require that the cleaner conduct weekly leak detection and repair. The remaining 8,400 area source perchloroethylene dry cleaners will be below the consumption cutoff and are only required to conduct bi-weekly leak detection and repair. |
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| j We have assumed that facilities below consumption cutoff perform leak detection and repairs on a bi-weekly basis. |
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| k Major sources contain an average of four machines. This task requires 1 hour times 4 machines per major source. |
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| l There are 13 existing private sector major sources subject to the NESHAP. |
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| m This task requires 0.25 hours times 4 machines per major source per week. |
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| n Area sources contain an average of one machine. This task requires 0.75 hours times 1 machine per area source. |
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| o Approximately 8,000 existing area sources are located in states that already require enhanced monitoring; therefore, 20,000 existing area sources are subject to the NESHAP's enhanced LDAR program. |
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| p No new major sources are expected for the three-year period of this ICR; therefore, no burden is associated with the development of carbon adsorber monitoring record systems. |
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| q Occurrences are based on twelve months rolling average of PCE consumption, determined once per month. |
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| r This is based on 28,000 area sources and 13 private sector major sources performing this task every year. |
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| s This task is performed primarily by technical staff. Management hours are only for a limited number of major sources, and we assume only three major sources will require managerial review. |
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| t Estimate includes hours for training one owner/operator and one employee. |
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| u This task requires an equal amount of management and technical employee hours. |
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| v Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
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| Table 1b: Annual Respondent Burden and Cost for Federal Facilities – NESHAP for Perchloroethylene Dry Cleaning Facilities (40 CFR Part 63, Subpart M) (Renewal) |
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|
|
| Burden Item |
A |
B |
C |
D |
E |
F |
G |
H |
|
|
|
| Hours per occurrence |
Occurrences per respondent per year |
Hours per respondent per year |
Respondents per yeara |
Technical hours per year |
Management hours per year |
Clerical hours per year |
Total cost per year ($)b |
|
|
|
|
|
(AxB) |
|
(CxD) |
(Ex0.05) |
(Ex0.10) |
|
|
|
|
| 1. Applications |
N/A |
|
|
|
|
|
|
|
|
Labor Rates: |
| 2. Survey and Studies |
N/A |
|
|
|
|
|
|
|
|
Management |
$65.71 |
| 3. Reporting Requirements |
|
|
|
|
|
|
|
|
|
Technical |
$48.75 |
| A. Familiarization with the regulatory requirements c |
1 |
1 |
1 |
7 |
0 |
7 |
0 |
$460 |
|
Clerical |
$26.38 |
| B. Required activities |
N/A |
|
|
|
|
|
|
|
|
|
|
| C. Create Information |
N/A |
|
|
|
|
|
|
|
|
|
|
| D. Gather existing information |
|
|
|
|
|
|
|
|
|
|
|
| Initial report information |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| Solvent consumption |
1 |
1 |
1 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| Compliance method report |
1 |
1 |
1 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| E. Write Report |
|
|
|
|
|
|
|
|
|
|
|
| Initial notification report |
1 |
1 |
1 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| Compliance method report c |
1 |
1 |
1 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| Solvent consumption report c |
0.25 |
1 |
0.25 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| Report-exceed consumption cutoff c |
1 |
1 |
1 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| Subtotal for Reporting Requirements |
|
|
|
|
7 |
$460 |
|
|
|
| 4. Recordkeeping Requirements |
|
|
|
|
|
|
|
|
|
|
|
| A. Familiarization with the regulatory requirements |
See 3A |
|
|
|
|
|
|
|
|
|
|
| B. Plan activities |
1 |
1 |
1 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| C. Implement activities |
|
|
|
|
|
|
|
|
|
|
|
| Above consumption cutoff: Weekly LDAR |
0.75 |
52 |
39 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| Below consumption cutoff: Bi-weekly LDAR |
0.75 |
26 |
19.5 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| Major: Monthly enhanced LDAR d, e |
1 |
48 |
48 |
7 |
336 |
17 |
34 |
$18,370 |
|
|
|
| Major: Weekly Carbon adsorber monitoring e, f |
0.25 |
208 |
52 |
7 |
364 |
18 |
36 |
$19,901 |
|
|
|
| Area: Monthly enhanced LDAR |
0.75 |
12 |
9 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| D. Develop record system |
|
|
|
|
|
|
|
|
|
|
|
| Solvent consumption |
1 |
1 |
1 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| Enhanced LDAR |
1 |
1 |
1 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| Monitoring records |
1 |
1 |
1 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| Carbon adsorber monitoring records g |
1 |
1 |
1 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| E. Time to enter information |
|
|
|
|
|
|
|
|
|
|
|
| Monthly records of solvent consumption h, i, j |
0.25 |
12 |
3 |
7 |
21 |
9 |
0 |
$1,615 |
|
|
|
| Above consumption cutoff: Records of weekly inspections |
0.25 |
52 |
13 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| Below consumption cutoff: Records of bi-weekly inspections |
0.25 |
26 |
6.5 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| Major: Enhanced LDAR |
See 4C |
|
|
|
|
|
|
|
|
|
|
| Major: Carbon adsorber monitoring |
See 4C |
|
|
|
|
|
|
|
|
|
|
| Area: Enhanced LDAR |
See 4C |
|
|
|
|
|
|
|
|
|
|
| F. Time to Train personnel |
|
|
|
|
|
|
|
|
|
|
|
| Leak detection |
1 |
2 |
2 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| G. Time for audits |
N/A |
|
|
|
|
|
|
|
|
|
|
| Subtotal for Recordkeeping Requirements |
|
|
|
|
835 |
$39,887 |
|
|
|
| Total Labor Burden and Cost (rounded) k |
|
|
|
|
842 |
$40,300 |
|
|
|
| Total Capital and O&M Cost (rounded) k |
|
|
|
|
|
|
|
$680 |
|
|
|
| Grand TOTAL (rounded) k |
|
|
|
|
|
|
|
$41,000 |
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|
|
|
|
|
|
|
|
|
|
|
|
|
| Assumptions |
|
|
|
|
|
|
|
|
|
|
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| a There are 7 existing major sources that are federal facilities and we assume that that no additional major sources will be subject to the NESHAP over the three-year period of this ICR. |
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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: Managerial rate of $65.71 (GS-13, Step 5, $41.07 + 60%), Technical rate of $48.75 (GS-12, Step 1, $30.47 + 60%), and Clerical rate of $26.38 (GS-6, Step 3, $16.49 + 60%). These rates are from the Office of Personnel Management (OPM) “2018 General Schedule” which excludes locality rates of pay. |
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| c This task requires management hours only. |
|
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| d Major sources contain an average of four machines. This task requires 1 hour times 4 machines per major source. |
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| e There are 7 existing public sector major sources subject to the NESHAP. |
|
|
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| f This task requires 0.25 hours times 4 machines per major source per week. |
|
|
|
| g No new major sources are expected for the three-year period of this ICR; therefore, no burden is associated with the development of carbon adsorber monitoring record systems. |
|
|
|
| h Occurrences are based on twelve months rolling average of PCE consumption, determined once per month. |
|
|
|
| i This is based on 7 major sources performing this task every year. |
|
|
|
| j This task is performed primarily by technical staff. Management hours are only for a limited number of major sources, and we assume only three major sources will require managerial review. |
|
|
|
| k Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
|
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|
| Table 2: Average Annual EPA Burden and Cost - NESHAP for Perchloroethylene Dry Cleaning Facilities (40 CFR Part 63, Subpart M) (Renewal) |
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|
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|
|
|
|
| Burden Item |
A |
B |
C |
F |
G |
H |
|
|
|
| EPA technical hrs per occurrence |
Occurrences per year a |
Technical hrs per year (AxB) |
Management hrs per year (Cx0.05) |
Clerical hrs per year (Cx0.10) |
Total cost per year ($) b |
|
|
|
| 1. Report review |
|
|
|
|
|
|
|
Labor Rates: |
| A. Initial notification report |
1 |
2,330 |
2,330 |
116.5 |
233 |
$127,389.26 |
|
Management |
$65.71 |
| B. Compliance method report c |
1 |
1,631 |
1,631 |
81.55 |
163.1 |
$89,172.48 |
|
Technical |
$48.75 |
| C. Solvent consumption report d |
1 |
699 |
699 |
34.95 |
69.9 |
$38,216.78 |
|
Clerical |
$26.38 |
| D. Report-exceed consumption cutoff e |
1 |
117 |
117 |
5.83 |
11.7 |
$6,369.46 |
|
|
|
| TOTAL (rounded) f |
|
|
5,490 |
$261,000 |
|
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|
|
|
|
|
|
|
|
|
|
|
| Assumptions: |
|
|
|
|
|
|
|
|
|
| a We have assumed that there are 28,000 existing area sources and that 2,330 sources will leave the industry and will be replaced by 2,330 new area sources per year over the next three years. There are 20 existing major sources and we assume that that no additional major sources will be subject to the NESHAP over the three-year period of this ICR. |
|
|
|
| b This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: Managerial rate of $65.71 (GS-13, Step 5, $41.07 + 60%), Technical rate of $48.75 (GS-12, Step 1, $30.47 + 60%), and Clerical rate of $26.38 (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. |
|
|
|
| c We estimate that 1,631 (70 percent) of the 2,330 new facilities will be above the consumption cutoff and are required to perform this task. |
|
|
|
| d We estimate that 699 (30 percent) of the 2,330 new facilities will be below the consumption cutoff (will consume less than 140 gallons of PCE per year) and are required to perform this task. |
|
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|
| e We assume that five percent of new sources will have to report-exceed consumption cutoff. |
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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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|
| Capital/Startup vs. Operation and Maintenance (O&M) Costs - Private Sector |
|
Capital/Startup vs. Operation and Maintenance (O&M) Costs - Public Sector |
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| (A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
|
(A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
| Continuous Monitoring Device |
Capital/Startup Cost for One Respondent |
Number of New Respondents |
Total Capital/Startup Cost, (B X C) |
Annual O&M Costs for One Respondent |
Number of Respondents with O&M |
Total O&M,
(E X F) |
|
Continuous Monitoring Device |
Capital/Startup Cost for One Respondent |
Number of New Respondents |
Total Capital/Startup Cost, (B X C) |
Annual O&M Costs for One Respondent |
Number of Respondents with O&M |
Total O&M,
(E X F) |
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|
|
|
|
| PID |
$3,300 |
0 |
$0 |
$95 |
13 |
$1,235 |
|
PID |
$3,300 |
0 |
$0 |
$95 |
7 |
$665 |
| HHD |
$250 |
2,330 |
$582,500 |
$14 |
20,000 |
$280,000 |
|
HHD |
$250 |
0 |
$0 |
$14 |
0 |
$0 |
| Initial notification & compliance report |
- |
- |
- |
$6.37 |
2,330 |
$14,842 |
|
Initial notification & compliance report |
- |
- |
- |
$6.37 |
0 |
$0 |
| Report exceed consumption cutoff |
- |
- |
- |
$6 |
117 |
$702 |
|
Report exceed consumption cutoff |
- |
- |
- |
$6 |
0 |
$0 |
| Photocopying |
- |
- |
- |
$2.40 |
28,013 |
$67,231 |
|
Photocopying |
- |
- |
- |
$2.40 |
7 |
$17 |
| Total |
|
|
$582,500 |
|
|
$364,010 |
|
Total |
|
|
$0 |
|
|
$682 |
| Total (rounded) |
|
|
$583,000 |
|
|
$364,000 |
|
Total (rounded) |
|
|
$0 |
|
|
$680 |
|
|
|
|
|
Total (rounded) |
$947,000 |
|
|
|
|
|
|
Total (rounded) |
$680 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| Number of Respondents |
|
|
|
|
|
|
|
|
|
|
Respondents That Submit Reports |
Respondents That Do Not Submit Any Reports |
|
|
|
|
|
|
|
|
|
|
|
(A) |
(B) |
(C) |
(D) |
(E) |
|
|
|
|
|
|
|
|
|
| Year |
Number of New Respondents 1 |
Number of Existing Respondents |
Number of Existing Respondents that keep records but do not submit reports |
Number of Existing Respondents That Are No Longer Subject 2 |
Number of Respondents (E=A+B+C-D) |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| 1 |
2,330 |
28,020 |
0 |
2,330 |
28,020 |
|
|
|
|
|
|
|
|
|
| 2 |
2,330 |
28,020 |
0 |
2,330 |
28,020 |
|
|
|
|
|
|
|
|
|
| 3 |
2,330 |
28,020 |
0 |
2,330 |
28,020 |
|
|
|
|
|
|
|
|
|
| Average |
|
|
|
|
28,020 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| 1 New respondent include sources with constructed, reconstructed and modified affected facilities. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| 2 We assume that the overall number of facilities will remain constant due to retirement of old existing facilities. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| Total Annual Responses - Private Sector |
|
Total Annual Responses - Public Sector |
|
|
|
|
| (A) |
(B) |
(C) |
(D) |
(E) |
|
(A) |
(B) |
(C) |
(D) |
(E) |
|
|
|
|
| Information Collection Activity |
Number of Respondents |
Number of Responses |
Number of Existing Respondents That Keep Records But Do Not Submit Reports |
Total Annual Responses E=(BxC)+D |
|
Information Collection Activity |
Number of Respondents |
Number of Responses |
Number of Existing Respondents That Keep Records But Do Not Submit Reports |
Total Annual Responses E=(BxC)+D |
|
|
|
|
| Write Initial Notification Report |
2,330 |
1 |
25,683 |
28,013 |
|
Write Initial Notification Report |
0 |
0 |
7 |
7 |
|
|
|
|
| Compliance Method Report |
1,631 |
1 |
0 |
1,631 |
|
Compliance Method Report |
0 |
0 |
0 |
0 |
|
|
|
|
| Solvent Consumption Report |
699 |
1 |
0 |
699 |
|
Solvent Consumption Report |
0 |
0 |
0 |
0 |
|
|
|
|
| Report Exceed Consumption Cutoff |
117 |
1 |
0 |
117 |
|
Report Exceed Consumption Cutoff |
0 |
0 |
0 |
0 |
|
|
|
|
|
|
|
Total |
30,460 |
|
|
|
|
Total |
7 |
|
|
|
|