| Table 1: Annual Respondent Burden and Cost – NESHAP for Reinforced Plastic Composites Production (40 CFR Part 63, Subpart WWWW) (Renewal) |
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122.20 |
153.55 |
61.51 |
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| Burden item |
(A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
(H) |
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| Person hours per occurrence |
No. of occurrences per respondent per year |
Person hours per respondent per year (C=AxB) |
Respondents per year a |
Technical person- hours per year (E=CxD) |
Management person hours per year (Ex0.05) |
Clerical person hours per year (Ex0.1) |
Cost, $ b |
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| 1. Applications |
N/A |
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| 2. Survey and Studies |
N/A |
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| 3. Acquisition, Installation, and Utilization of Technology and Systems |
N/A |
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| 4. Reporting Requirements |
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| A. Familiarization with Regulatory Requirementsc |
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| i. Facilities with 4 groups of operations |
1.00 |
1 |
1 |
416.64 |
416.64 |
20.83 |
41.66 |
$56,674.9 |
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| ii. Facilities with 5 groups of operations |
1.25 |
1 |
1 |
31.36 |
39.20 |
1.96 |
3.92 |
$5,332.3 |
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| iii. Familiarize with updated regulatory requirements e |
4.00 |
1 |
4 |
0 |
0 |
0 |
0 |
$0 |
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| B. Required activities: Sources with add-on controls f |
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| i. Initial performance test d, f |
320 |
1 |
320 |
0 |
0 |
0 |
0 |
$0 |
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| ii. Establish operating parameters d, f |
10 |
1 |
10 |
0 |
0 |
0 |
0 |
$0 |
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| iii. Re-evaluating startup, shutdown, and malfunction e requirements e |
4 |
1.00 |
4 |
0 |
0 |
0 |
0 |
$0 |
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| iv. Monitoring of operating parameters and equipment f |
See 5E |
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| C. Required activities: Sources using pollution prevention measures |
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| i. Develop recordkeeping system g |
See 5D |
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| ii. Enter information into recordkeeping system |
See 5E |
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| iii. Work practice requirements. f |
4 |
12 |
48 |
448 |
21504.00 |
1075.20 |
2150.40 |
$2,925,157 |
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| D. Gather Existing Information |
See 5D, 5E |
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| E. Write report a |
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| i. Initial notification that existing sources are subject to the standard d |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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| ii. Notification for new major sources d |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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| iii. Request for compliance extension d |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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| iv. Notification of special compliance requirements d |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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| v. Notification of performance tests d |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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| vi. Notification of compliance status d |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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| x. Semiannual compliance reports for all sources g |
8 |
2 |
16 |
448 |
7168 |
358 |
717 |
$975,052.29 |
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| Subtotal for Reporting Requirements |
33,497 |
$3,962,216 |
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| 5. Recordkeeping Requirements |
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| A. Familiarization with Regulatory Requirements |
See 4A |
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| B. Plan activities |
See 4B |
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| C. Implement activities |
See 4B |
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| D. Develop record system (spreadsheets): d |
6 |
1 |
6 |
0 |
0 |
0 |
0 |
$0 |
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| E. Time to enter and transmit all information into record system |
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| i. Record information |
6 |
1 |
6 |
448 |
2688 |
134 |
269 |
$365,644.61 |
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| F. Develop operator training course and keep records of operators taken it d |
10 |
1 |
10 |
0 |
0 |
0 |
0 |
$0 |
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| G. Time to train personnel: h |
4 |
1 |
4 |
448 |
1792 |
90 |
179 |
$243,763 |
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| iv. Familiarize with CEDRI and CDX registration e |
4 |
1 |
4 |
0 |
0 |
0 |
0 |
$0 |
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| H. Time for audits |
N/A |
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| Subtotal for Recordkeeping Requirements |
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5,152 |
$609,408 |
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| TOTAL LABOR BURDEN AND COST (rounded) i: |
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38,600 |
$4,570,000 |
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| Capital and O&M Cost (rounded) i: |
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$0 |
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| TOTAL COST (rounded) i: |
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$4,570,000 |
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| Assumptions: |
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| a There is an average of 448 existing reinforced plastic composites facilities (or RPC) subject to NESHAP subpart WWWW. We have assumed that there will be no new RPC facilities each year over the three year period of this ICR. We have assumed that 93 percent of the new RPC facilities will consist of an average of four groups of operations and 7 percent will consist of five groups of operations. |
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6 |
hrs/reponse |
| b This ICR uses the following labor rates: $153.55 per hour for Executive, Administrative, and Managerial labor; $122.20 per hour for Technical labor, and $61.51 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2021, ”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 We have assumed 93% of respondents have 4 groups of operations and 7% of respondents have 5 groups of operations. |
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| d We have assumed no new respondents over the next three years due to trends in industry consolidation. Because there are no new respondents, we expect no burden for this requirement. |
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| e This burden item includes initial rulemaking activities from the 2020 RTR. It reflects one time activities for existing respondents completed within the first year of promulgation. As such we estimate no burden for this requirement and have adjusted the number of respondents to zero to reflect this. |
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| f We have assumed that all of existing facilities are complying with the regulations by using pollution prevention measures. |
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| g We have assumed that each respondent will take 8 hours two times per year to complete the semiannual compliance report. |
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| h We have assumed that it takes four hours to train personnel. |
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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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| Table 2: Average Annual EPA Burden and Cost – NESHAP for Reinforced Plastic Composites Production (40 CFR Part 63, Subpart WWWW) (Renewal) |
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51.23 |
69.04 |
27.73 |
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| Burden item |
(A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
(H) |
| Person hours per occurrence |
No. of occurrences per respondent per year |
Person hours per respondent per year (C=AxB) |
Respondents per year a |
Technical person- hours per year (E=CxD) |
Management person hours per year (Ex0.05) |
Clerical person hours per year (Ex0.1) |
Cost, $ b |
| Enter and update information into agency recordkeeping system c |
4 |
1 |
4 |
448 |
1792 |
89.6 |
179.2 |
$102,959 |
| Review initial notification for existing sources d |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
| Notification for new major sources d |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
| Review request for compliance extension d |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
| Review special compliance requirements d |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
| Review initial performance test and test plan d, e |
12 |
1.2 |
14.4 |
0 |
0 |
0 |
0 |
$0 |
| Report of performance test results including operating parameters e |
12 |
1.2 |
14.4 |
0 |
0 |
0 |
0 |
$0 |
| Semiannual compliance reports for all sources f |
4 |
2 |
8 |
448 |
3584 |
22.4 |
358.4 |
$195,093 |
| Review compliance status d,g |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
| TOTAL ANNUAL BURDEN AND COST (rounded)h |
6,030 |
$298,000 |
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| Assumptions: |
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| a There is an average of 448 existing reinforced plastic composites facilities (or RPC) subject to NESHAP subpart WWWW. We have assumed that there will be no new RPC facilities each year over the three year period of this ICR. Furthermore, we have assumed that 93 percent of the new RPC facilities will consist of an average of four groups of operations and 7 percent will consist of five groups of operations. |
| b This cost is based on the following labor rates: Managerial rate of $69.04 (GS-13, Step 5, $43.15 + 60%), Technical rate of $51.23 (GS-12, Step 1, $32.02 + 60%), and Clerical rate of $27.73 (GS-6, Step 3, $17.33 + 60%). These rates are from the Office of Personnel Management (OPM), 2021 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. |
| c We have assumed that respondents will each take 4 hours to enter and update information into agency recordkeeping system. |
| d We have assumed that there will be no new sources over the three-year period of this ICR. |
| e We have assumed that all of the existing facilities are complying with the regulations by using pollution prevention measures. |
| f We have assumed that it will take four hours two times per year to review the semiannual compliance report. |
| g We have assumed that it will take 2 hours to review the compliance status notification. |
| h Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |