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| Capital/Startup vs. Operation and Maintenance (O&M) Costs |
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| (A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
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| 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, |
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|
(E X F) |
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| O&M |
$0 |
0 |
$0 |
$1,505.00 |
50 |
$75,250 |
|
| LDAR |
$41,254 |
0 |
$0 |
$11,876 |
50 |
$593,800 |
|
| PRD Monitoring Equipment |
$27,000 |
0 |
$0 |
$4,000 |
50 |
$200,000 |
|
| Storage Tanks Duct Work1 |
$76,412 |
0 |
$0 |
$20,797 |
1 |
$20,797 |
|
| Photocopy and Postage |
|
|
|
$22.71 |
100 |
$2,271 |
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| Total |
|
|
$0 |
|
|
$892,000 |
$892,000 |
| Note: Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
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| 1 Costs shown are the total costs for the estimated 21 additional tanks captured under the new 2015 threshold from the March 2015 final rule. |
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| 2 Reflects updated costs for PRD monitoring for stationary sources from the January 29, 2018 final rule (83 FR 3986). The annualized costs per facility (assuming a 15-year equipment life and a seven percent interest rate) are estimated to be approximately $4,000. See memorandum from Carey, A., EPA, “Pressure Relief Device Control Options and Impacts for Off-Site Waste and Recovery Operations (OSWRO) June 26, 2017”, Docket Id. No. EPA-HQ-OAR-2012-0360-0133. |
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|
120.27 |
141.06 |
58.67 |
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| Burden Items |
(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 (CxD) |
(F) Managerial person hours per year (Ex0.05) |
(G) Clerical person hours per year (Ex0.1) |
(H) Total costs per year $ b |
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| 1. Applications |
N/A |
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| 2. Survey and Studies |
N/A |
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| 3. Reporting Requirements |
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| A. Familiarize with rule requirement c ,d |
4 |
1 |
4 |
50 |
200 |
10 |
20 |
$26,638 |
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| B. Required Activities |
See 4C |
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| C. Create Information |
See 4C |
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| D. Gather Existing Information c |
See 4C |
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| E. Write Reports |
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| Initial Notification Report c, e |
1 |
1 |
1 |
0 |
0 |
0 |
0 |
$0 |
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| Performance Test Notification Report c, e |
1 |
1 |
1 |
0 |
0 |
0 |
0 |
$0 |
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| Compliance Status Notification c, e |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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| Performance Test Reports c, e |
8 |
1 |
8 |
0 |
0 |
0 |
0 |
$0 |
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| Startup/Shutdown/Malfunction Report |
N/A |
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|
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| Semiannual Summary Report f |
8 |
2 |
16 |
50 |
800 |
40 |
80 |
$106,552 |
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| Subtotal for Reporting Requirements |
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|
1,150 |
$133,190 |
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| 4. Recordkeeping Requirements |
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| A. Familiarize with rule requirements c |
See 3A |
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| B. Planned Activities c |
40 |
1 |
40 |
0 |
0 |
0 |
0 |
$0 |
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| C. Implementation of Activities |
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| a. VOHAP concentration determination |
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| Commercial Facilities g |
2 |
260 |
520 |
25 |
13,000 |
650 |
1,300 |
$1,731,470 |
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|
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| Other Facilities h |
2 |
12 |
24 |
25 |
600 |
30 |
60 |
$79,914 |
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| b. Vapor Pressure Determination |
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| Commercial Facilities g |
1 |
260 |
260 |
25 |
6,500 |
325 |
650 |
$865,735 |
|
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| Other Facilities h |
1 |
12 |
12 |
25 |
300 |
15 |
30 |
$39,957 |
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|
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| c. Control Equipment Visual Inspection |
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| Large Cover |
0.25 |
10 |
2.5 |
50 |
125 |
6.25 |
12.5 |
$16,649 |
Note to EPA: These costs were omitted from the prior ICR file uploaded to reginfo, however, are included in the proposal and final rule RTR ICRs uploaded to the docket (which were approved following the last renewal). We have added them back in.See https://www.regulations.gov/document?D=EPA-HQ-OAR-2012-0360-0099. |
|
|
| Small Cover |
0.05 |
1000 |
50 |
50 |
2500 |
125 |
250 |
$332,975 |
Note to EPA: These costs were omitted from the prior ICR file uploaded to reginfo, however, are included in the proposal and final rule RTR ICRs uploaded to the docket (which were approved following the last renewal). We have added them back in.See https://www.regulations.gov/document?D=EPA-HQ-OAR-2012-0360-0099. |
|
|
| Closed Vent System |
0.5 |
5 |
2.5 |
50 |
125 |
6.25 |
12.5 |
$16,649 |
Note to EPA: These costs were omitted from the prior ICR file uploaded to reginfo, however, are included in the proposal and final rule RTR ICRs uploaded to the docket (which were approved following the last renewal). We have added them back in.See https://www.regulations.gov/document?D=EPA-HQ-OAR-2012-0360-0099. |
|
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| d. Control Equipment Leak Monitoring |
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| Cover Vented to Control Device |
1 |
5 |
5 |
50 |
250 |
12.5 |
25 |
$33,298 |
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| Closed Vent System |
1 |
5 |
5 |
50 |
250 |
12.5 |
25 |
$33,298 |
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| e. Control Devices |
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| Performance Determination c |
40 |
1 |
40 |
0 |
0 |
0 |
0 |
$0 |
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| Continuous Monitoring System |
8 |
5 |
40 |
50 |
2,000 |
100 |
200 |
$266,380 |
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| f. LDAR Program |
|
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| Identify Affected Waste Streams c |
40 |
1 |
40 |
0 |
0 |
0 |
0 |
$0 |
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| Perform Monitoring/Repair |
80 |
1 |
80 |
50 |
4,000 |
200 |
400 |
$532,760 |
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| g. PRD monitoring |
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| Identification of PRD devices c |
8 |
1 |
8 |
0 |
0 |
0 |
0 |
$0 |
|
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| Perform Monitoring/Repair |
16 |
1 |
16 |
50 |
800 |
40 |
80 |
$106,552 |
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| D. Develop Record System c |
|
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| Control Equipment |
16 |
1 |
16 |
0 |
0 |
0 |
0 |
$0 |
|
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| LDAR Program |
40 |
1 |
40 |
0 |
0 |
0 |
0 |
$0 |
|
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|
| PRD Program |
8 |
1 |
8 |
0 |
0 |
0 |
0 |
$0 |
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| E. Time to Enter Information |
|
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|
|
|
|
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| Cover Designs |
40 |
1 |
40 |
0 |
0 |
0 |
0 |
$0 |
|
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| Control Device Design c |
40 |
1 |
40 |
0 |
0 |
0 |
0 |
$0 |
|
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| Control Equipment Testing c |
1 |
1 |
1 |
0 |
0 |
0 |
0 |
$0 |
|
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| Control Equipment Inspections c |
1 |
1 |
1 |
50 |
50 |
2.5 |
5 |
$6,660 |
|
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|
| Control Equipment Monitoring |
1 |
1 |
1 |
50 |
50 |
2.5 |
5 |
$6,660 |
|
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| Control Device CMS |
1 |
52 |
52 |
50 |
2,600 |
130 |
260 |
$346,294 |
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| LDAR Program |
4 |
16 |
64 |
50 |
3,200 |
160 |
320 |
$426,208 |
|
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| PRD Program |
2 |
16 |
32 |
50 |
1,600 |
80 |
160 |
$213,104 |
|
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| Off-site Material Determinations |
1 |
52 |
52 |
50 |
2,600 |
130 |
260 |
$346,294 |
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| F. Time to Train Personnel c |
|
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| Waste Determination Methods |
40 |
1 |
40 |
0 |
0 |
0 |
0 |
$0 |
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| Control equipment inspect and monitor |
40 |
1 |
40 |
0 |
0 |
0 |
0 |
$0 |
|
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| LDAR Program |
8 |
1 |
8 |
0 |
0 |
0 |
0 |
$0 |
|
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| PRD Program |
8 |
1 |
8 |
0 |
0 |
0 |
0 |
$0 |
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| G. Time for Audits |
N/A |
|
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| Subtotal for Recordkeeping Requirements |
|
|
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|
46,633 |
$5,400,855 |
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| TOTAL ANNUAL BURDEN AND COSTS (rounded): i |
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|
47,800 |
$5,530,000 |
|
478 |
hr per resp |
| Capital and O&M Cost (see Section 6(b)(iii)): i |
|
|
|
|
|
|
|
$892,000 |
|
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| TOTAL COST: j |
|
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|
|
|
$6,420,000 |
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| Assumptions: |
|
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| a We have assumed that there are approximately 50 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three years. |
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| b This ICR uses the following labor rates: Managerial $141.06; Technical $120.27; and Clerical $58.67. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2019, “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 activity is a one-time activity following promulgation of the March 15, 2018 final rule. |
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| d It is assumed that it will take 4 hours to read instructions. |
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| e It is assumed that there will be no new sources. |
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| f The burden of one annual summary report was included in the burden estimate for the semiannual report. |
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| g It is assumed that 50 percent of the facilities, the owner or operator manages, for a fee, off-site materials received from other generators. |
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| h It is assumed that 50 percent of the owners or operators accept the off-site material at another location and ship it to the facility for storage, treatment, or disposal. |
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| i Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
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|
|
49.44 |
66.62 |
26.75 |
|
| Activity |
(A) EPA Hours/ Occurrence |
(B) Occurrences/ Plant/ Year |
(C) EPA Hours/ Year (AxB) |
(D) Plants/ Year a |
(E) Technical Hours/ Year (CxD) |
(F) Managerial Hours/ Year (Ex0.05) |
(G) Clerical Hours/ Year (Ex0.1) |
(H) Costs, $ b |
| Report Review |
|
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| New Plants c, d |
|
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| Initial notification (PRD) |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
| Performance test notification |
1 |
1 |
1 |
0 |
0 |
0 |
0 |
$0 |
| Compliance status notification |
4 |
1 |
4 |
0 |
0 |
0 |
0 |
$0 |
| Performance test report e |
16 |
1 |
16 |
0 |
0 |
0 |
0 |
$0 |
| Existing Plants |
|
|
|
|
|
|
|
|
| Startup/shutdown report |
N/A |
| Semiannual summary report f |
4 |
2 |
8 |
50 |
400 |
20 |
40 |
$22,178 |
| TOTAL ANNUAL BURDEN AND COST (rounded) g |
|
|
|
|
460 |
$22,200 |
|
|
|
|
|
|
|
|
|
| Assumptions: |
|
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|
|
|
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| a We have assumed that there are approximately 50 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three years. |
|
|
|
|
|
|
|
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| b This ICR uses the following labor rates: Managerial $66.62; Technical $49.44; and Clerical $26.75. These rates are from the Office of Personnel Management (OPM), 2019 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 There will be no travel expenses associated with this ICR since we have assumed that no new sources will become subject to this rule over the three year period of this ICR. |
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| d It is assumed that there will be no new sources over the three year period of this ICR. |
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| e It is assumed that it will take 16 hours to review each performance test report. |
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| f It is assumed that each facility will take 4 hours twice a year to submit report. |
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| g Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
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