| Table 1: Annual Respondent Burden and Cost – NSPS for Volatile Organic Liquid Storage Vessels (40 CFR Part 60, Subpart Kb) (Proposed Amendments) |
|
|
|
|
|
|
|
|
|
|
Salaries taken for NAICS 331500: Foundries |
|
|
|
|
|
|
|
|
|
73.75 |
144.69 |
48.09 |
|
|
|
May 2019 |
https://www.bls.gov/oes/current/naics4_331500.htm |
|
|
|
| Burden item |
(A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
(H) |
|
|
|
|
|
110% |
|
| Person hours per occurrence |
No. of occurrences per respondent per year |
Person hours per respondent per year |
Respondents per year a |
Technical person- hours per year |
Management person hours per year |
Clerical person hours per year |
Total Cost per year, ($) b |
|
|
Occupation Code |
Title |
Mean Hourly Rate |
Overhead |
Estimated Total Pay with Benefits |
|
|
(C=AxB) |
|
(E=CxD) |
(F=Ex0.05) |
(G=Ex0.10) |
|
|
|
11-0000 |
Mgmt Occup |
68.9 |
75.79 |
144.69 |
| 1. Applications |
N/A |
|
|
|
|
|
|
|
|
|
20/80 split |
Technical |
35.12 |
38.63 |
73.75 |
| 2. Surveys and studies |
N/A |
|
|
|
|
|
|
|
|
|
43-0000 |
Office and Admin Support |
22.9 |
25.19 |
48.09 |
| 3. Reporting requirements |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| a. Familiarize with regulatory requirements c |
No change |
|
|
|
|
|
|
|
|
|
17-2081 |
Envir Engr |
51.14 |
|
107.39 |
| b. Required activities d |
|
|
|
|
|
|
|
|
|
|
49-0000 |
Maintenance/Inspections |
31.11 |
|
65.33 |
| i. Additional top-side inspections a |
8 |
1 |
8 |
385 |
3080 |
154 |
308 |
$264,244 |
|
|
|
|
|
|
|
| ii. Additional internal inspections a |
12 |
1 |
12 |
-385 |
-4620 |
-231 |
-462 |
($396,366) |
|
|
|
|
|
|
|
| iii. Emptying/Degassing e |
18.4 |
1 |
18.4 |
-210 |
-3864 |
-193.2 |
-386.4 |
($331,506) |
|
|
|
|
|
|
|
| c. Create information f |
No change |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| d. Gather existing information f |
No change |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| e. Write report f |
No change |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| Subtotal for Reporting Requirements |
|
|
|
|
-6,214.6 |
($463,628) |
|
|
|
|
|
|
|
| 4. Recordkeeping requirements f |
No change |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| Subtotal for Recordkeeping Requirements |
|
|
|
|
0 |
$0 |
|
|
|
|
|
|
|
| TOTAL LABOR BURDEN AND COST (rounded) g |
|
|
|
|
-6,210 |
($464,000) |
|
|
|
|
|
|
|
| CAPITAL AND O&M COST (rounded) g |
|
|
|
|
|
|
|
($466,000) |
|
|
|
|
|
|
|
| GRAND TOTAL (rounded) g |
|
|
|
|
|
|
|
($930,000) |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| Assumptions: |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| a We have assumed that the average number of respondents that will be subject to revised requirements will be 385 per year. This is based on our estimate of 3,500 existing IFR storage vessels subject to the NSPS. We have assumed 10 percent or 350 storage vessels would be subject to the 5-year internal inspection requirement and the remainder (3,150) subject to the 5-year internal inspection requirement. We have assumed that there will be no change in impacts for any new sources during the next three years of this ICR. Therefore, the annual number of impacted inspections is 350/5 + 3150/10 = 385/year |
|
|
|
|
|
|
|
| b This ICR uses the following labor rates based on the Bureau of Labor Statistics (BLS) data. Technical, management, and clerical average hourly rates for private industry workers were taken from the May 2019 National Industry-Specific Occupational Employment and Wage Estimates for NAICS 325000 (Chemical Manufacturing) and NAICS 326000 (Petroleum and Coal Products Manufacturing). The technical rates are further blended between environmental engineer (20 percent) and maintenance and repair staff (80 percent). The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry. Fully burdened hourly rates are: $144.69 for management; $73.75 for technical; and $48.09 for clerical. |
|
|
|
|
|
|
|
| c The previous ICR assumed that all respondents will have to familiarize with regulatory requirements each year. There are no changes in this burden. |
|
|
|
|
|
|
|
| d We have listed only those activities that are impacted by the proposed amendments. There are other required activities required by the NSPS. |
|
|
|
|
|
|
|
| e We assumed degassing would occur every 20 years for maintenance in the absence of the internal inspection requirement. Without the internal inspection requirement, there would be 175 degassing and emptying events per year (3500/20). Therefore, the change in the number of degassing and emptying events is 210 per year (385-175). |
|
|
|
|
|
|
|
| f We assumed there would be no changes in these requirements as a result of the proposed amendments. |
|
|
|
|
|
|
|
| g Totals burden and costs have been rounded to 3 significant digits. Figures may not add exactly due to rounding. |
|
|
|
|
|
|
|
|
| Capital/Startup vs. Operation and Maintenance (O&M) Costs |
|
|
|
|
|
|
|
| (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) |
| Degassing Contols |
$0 |
0 |
$0 |
$7,400 |
-63 |
($466,200) |
|
|
|
|
|
|
|
| Total b |
|
|
$0 |
|
|
($466,000) |
| a Assumes 30 % or 63 controlled degassing events are avoided per year. |
|
|
|
|
|
|
| b Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
|
|
|
|
|
|