|
|
|
|
|
May 2017 Labor Rates |
|
|
|
|
|
|
|
|
107.50 |
121.02 |
40.01 |
|
| Burden item |
(A) Person hours per occurrence |
(B) No. of occurrences per respondent per year |
(C) Person hours per respondent per year (A x B) |
(D) Respondents per year a |
(E) Technical person- hours per year (C x D) |
(F) Management person hours per year (E x0.05) |
(G) Clerical person hours per year (E x 0.1) |
(H) Total Cost per year b |
| 1. Applications |
N/A |
|
|
|
|
|
|
|
| 2. Survey and Studies |
N/A |
|
|
|
|
|
|
|
| 3. Reporting requirements |
|
|
|
|
|
|
|
|
| A. Familiarization with Regulatory Requirements b |
4 |
1 |
4 |
90 |
360 |
18 |
36 |
$42,319 |
| B. Required activities b |
|
|
|
|
|
|
|
|
| Develop plans for demonstrating compliance |
80 |
1 |
80 |
9 |
720 |
36 |
72 |
$84,637 |
| C. Create information |
N/A |
|
|
|
|
|
|
|
| D. Gather existing information |
See 4E |
|
|
|
|
|
|
|
| E. Write Report |
|
|
|
|
|
|
|
|
| Initial notification of intent to construct/reconstruction c |
8 |
1 |
8 |
1 |
8 |
0.4 |
0.8 |
$940 |
| Application for construction/ reconstruction c |
8 |
1 |
8 |
1 |
8 |
0.4 |
0.8 |
$940.42 |
| Notification of commencement of construction/reconstruction c |
8 |
1 |
8 |
1 |
8 |
0.4 |
0.8 |
$940.42 |
| Notification of anticipated startup c |
8 |
1 |
8 |
9 |
72 |
3.6 |
7.2 |
$8,463.74 |
| Notification of actual startup c |
8 |
1 |
8 |
9 |
72 |
3.6 |
7.2 |
$8,463.74 |
| Notification of compliance status c,d |
24 |
1 |
24 |
1 |
24 |
1.2 |
2.4 |
$2,821.25 |
| Annual compliance certification d |
24 |
1 |
24 |
Denise Bevington:
Was 90 in proposal ICR, but the 1 new facility in Year 1 has correctly been removed for Year 1 because this report does not apply in Year 1 for the new source in Year 1. However, this report does apply in Year 2 for the 1 new source in Year 1 (and in Year 3 for the 1 new source in each Year 1 and 2). Given that the burden estimate is the same for rows 18 and 19, this approach produces the correct estimate in burden hours and dollars.
89 |
2,136 |
106.8 |
213.6 |
$251,091.07 |
| Notification of deviation report e |
8 |
1 |
8 |
1 |
8 |
0.4 |
0.8 |
$940.42 |
| Notification of performance tests f |
24 |
1 |
24 |
0 |
0 |
0 |
0 |
$0 |
| Initial startup report g |
4 |
1 |
4 |
9 |
36 |
1.8 |
3.6 |
$4,231.87 |
| Subtotal for Reporting Requirements |
|
|
|
|
3,928 |
$405,790 |
| 4. Recordkeeping requirements |
|
|
|
|
|
|
|
|
| A. Familiarization with Regulatory Requirements b |
See 3A |
|
|
|
|
|
|
|
| B. Develop record system |
N/A |
|
|
|
|
|
|
|
| C. Time to enter information |
|
|
|
|
|
|
|
|
| Solvent inventory d, h |
8 |
12 |
96 |
90 |
8,640 |
432 |
864 |
$1,015,649.28 |
| HAP content of solvent d, h |
8 |
12 |
96 |
90 |
8,640 |
432 |
864 |
$1,015,649.28 |
| Oilseed inventory d, h |
8 |
12 |
96 |
90 |
8,640 |
432 |
864 |
$1,015,649.28 |
| Records for periods of initial startup (new or reconstructed sources)g |
8 |
6 |
48 |
1 |
48 |
2.4 |
4.8 |
$5,642.50 |
| Records for periods of initial startup (significantly modified sources) g |
8 |
3 |
24 |
8 |
192 |
9.6 |
19.2 |
$22,569.98 |
| E. Time to train personnel b |
40 |
1 |
40 |
1 |
40 |
2 |
4 |
$4,702 |
| F. Time for audits |
N/A |
|
|
|
|
|
|
|
| Subtotal for Recordkeeping Requirements |
|
|
|
|
30,130 |
$3,079,862 |
| TOTAL LABOR BURDEN AND COST (rounded)i |
|
|
|
|
34,100 |
$3,490,000 |
| TOTAL CAPITAL AND O&M COST (rounded)i |
|
|
|
|
|
|
|
$0 |
| GRAND TOTAL (rounded)i |
|
|
|
|
|
|
|
$3,490,000 |
|
|
|
|
|
|
262 |
hr / response |
|
|
|
|
|
|
|
|
|
|
| Assumptions: |
|
|
|
|
|
|
|
|
| a This ICR uses the following labor rates: $121.02 per hour for Executive, Administrative, and Managerial labor; $107.50 per hour for Technical labor, and $40.01 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, May 2017, National Industry-Specific Occupational Employment and Wage Estimates NAICS 311200 - Grain and Oilseed Milling. The rates are from column 8, "Mean HourlyWage" and have been increased by 110 percent to account for the benefit packages available to those employed by private industry. |
| b We have assumed that there are approximately 89 existing sources that are subject to the standard. We have assumed that there will be a growth rate of one new or reconstructed source per year, on average, and 8 existing sources with significant modifications per year, over the three-year period of this ICR based on input from the affected industry. Therefore, we assume that 90 respondents will have to familiarize with the revised regulatory requirements. |
| c We have assumed that one new or reconstructed source per year will submit initial notifications over the next three years. Eight existing sources with significant modifications will be required to submit initial notifications for anticipated startup and actual startup per the requirements of 40 CFR 63.2860(c). |
| d We have assumed that there are approximately 89 sources that are subject to the standard and will submit annual compliance certifications and maintain records over the next three years. The initial compliance status notification does not apply to existing sources. It is required for new and reconstructed sources. |
| e We have assumed that one source will submit a notification of deviation report each year. |
|
|
|
|
|
|
|
|
| f Based on available data, we have assumed that no facilities are currently using a control device and would be required to submit a notification of performance test. |
|
|
|
|
|
|
|
|
| g We have estimated that one new or reconstructed source and 8 significantly modified sources per year will keep records for work practices and submit an initial startup report each year. |
|
|
|
|
|
|
|
|
| h We have assumed that it will take eight hours once per month for data to be recorded. |
|
|
|
|
|
|
|
|
| i Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
|
|
|
|
|
|
|
|
|
|
|
|
|
2018 Schedule |
|
|
|
|
|
|
|
|
48.75 |
65.71 |
26.38 |
|
| Activity |
(A) EPA person- hours per occurrence |
(B) No. of occurrences per plant per year |
(C) EPA person- hours per plant per year (AxB) |
(D) Plants per year a |
(E) Technical person- hours per year (CxD) |
(F) Management person-hours per year (Ex0.05) |
(G) Clerical person-hours per year (Ex0.1) |
(H) Cost, $b |
| Report review |
|
|
|
|
|
|
|
|
| Initial notification b,c |
8 |
1 |
8 |
1 |
8 |
0.4 |
0.8 |
$437 |
| Review approve construction/reconstruction application c |
24 |
1 |
24 |
1 |
24 |
1.2 |
2.4 |
$1,312.16 |
| Notification of construction/reconstruction c |
24 |
1 |
24 |
1 |
24 |
1.2 |
2.4 |
$1,312.16 |
| Notification of anticipated startup c |
4 |
1 |
4 |
9 |
36 |
1.8 |
3.6 |
$1,968.25 |
| Notification of actual startup c |
4 |
1 |
4 |
9 |
36 |
1.8 |
3.6 |
$1,968.25 |
| Review of compliance status c |
16 |
1 |
16 |
1 |
16 |
0.8 |
1.6 |
$874.78 |
| Review of annual compliance certification d |
16 |
1 |
16 |
Denise Bevington:
Same issue as for cell E19 in the Indsutry Table.
89 |
1,424 |
71.2 |
142.4 |
$77,855.06 |
| Review of deviation report e, f |
4 |
1 |
4 |
1 |
4 |
0.2 |
0.4 |
$218.69 |
| Review of performance test g |
8 |
1 |
8 |
0 |
0 |
0 |
0 |
$0 |
| Review of initial startup report h |
4 |
1 |
4 |
9 |
36 |
1.8 |
3.6 |
$1,968.25 |
| TOTAL COST (rounded)i |
|
|
|
|
1,850 |
$87,900 |
|
|
|
|
|
|
|
|
|
| Assumptions: |
|
|
|
|
|
|
|
|
| a This cost is based on the following hourly labor rates times a 1.6 benefits multiplication factor to account for government overhead expenses: $65.71 for Managerial, $48.75 for Technical, and $26.38 Clerical. These rates are from the Office of Personnel Management (OPM) “2018 General Schedule” which excludes locality rates of pay. |
|
[Threaded comment]
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Comment:
A re-read of 40 CFR 63.2860(c) and (d) indicates this isn't required of significantly modified sources.
b We have assumed that there will be one new or reconstructed facility per year, and 8 existing sources with significant modifications per year, on average over the next three years. The initial compliance status notification does not apply to existing sources as that is a one-time requirement. It is required for reconstructed and new sources. |
| c We have assumed that one new or reconstructed source per year will submit initial notifications over the next three years. Eight existing sources with significant modifications per year will be required to submit initial notifications for anticipated startup and actual startup per the requirements of 40 CFR 63.2860(c). |
| d We have assumed that there are approximately 89 sources that are subject to the standard. |
| e We have assumed that it will take four hours to review the deviation report. |
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| f We have assumed that one source will submit a notification of deviation report each year. |
|
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| g Based on available data, we have assumed that no facilities are currently using a control device and would be required to submit a notification of performance test. |
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| h We have estimated that one new or reconstructed source and 8 significantly modified sources will submit an initial startup report each year. |
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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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