| Annual Respondent Burden and Cost by Type of Party |
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| Obligated Parties* |
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| Information Collection Activity |
Hours and Cost |
Total Hours and Cost |
Forms & Notes |
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| Citation |
Activity |
Standard Industry Mix Hours/ Response |
Clerical Only Hours/ Response |
Purchased Services Hours/ Response |
Total Cost/ Response (dollars) |
Number of Respondents |
Number of Responses per party/year |
Total Number of Responses per Year |
Total Hours/ Year |
Total Cost/Year |
Non-Labor Only Portion of Column K (All Purchased Services ) |
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| 80.XXXX |
Reporting: Preparation/submission of notification letter to EPA |
0.33 |
0.00 |
0.00 |
30 |
13 |
1 |
13 |
4 |
395 |
CBP (Respondents represent a subset of small refineries. ) |
0 |
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| 80.XXXX |
Recordkeeping: retain notification letter sent to EPA |
0.10 |
0.00 |
0.00 |
9 |
13 |
1 |
13 |
1 |
120 |
CBP (Respondents are a subset of small refineries.) |
0 |
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| 80.XXXX |
Recordkeeping: retain methods and variables to calculate RIN retirements |
0.25 |
0.00 |
0.00 |
23 |
13 |
4 |
52 |
13 |
1,196 |
CBP (Burden estimated as one hour per per year.) |
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| GRAND TOTAL |
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39 |
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78 |
19 |
1,710 |
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| Notes to the Table: |
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| * We assume 13 total respondents, one response per respondent, all of which will come in the first year. (We annualized the burden by dividing the hours by 3.) |
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| ALL DECIMALS ARE ROUNDED TO THE NEAREST WHOLE NUMBER. |
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| Labor Costs |
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| Labor Type |
Labor Cost/hour |
Labor + Overhead/ houra |
Portion attributed/hour |
Employer Cost/hour |
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| Managerial (CEO - 11-1011) |
126.33 |
253 |
0.05 |
12.65 |
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| Professional/Technical (Refinery Operators - 51-8093) |
41.32 |
83 |
0.7 |
58.1 |
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| Clerical (Secretaries and Administrative Assistants 43-6010) |
26.88 |
54 |
0.2 |
10.8 |
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| Legal (Lawyer 23-1011) |
98.36 |
197 |
0.05 |
9.85 |
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| Total Employer Cost/hour |
92 |
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| Purchased Servicesb |
230 |
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| a Overhead is calculated to be equal to the cost of labor; i.e. 2x labor cost, rounded up. |
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| b The cost of purchased services (for example, cost of attest auditors) is calculated at 2.5 times the Total Employer Cost. Increased from 2 times (as a result of industry consultation/comment. |
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| “May 2021 National Industry-Specific Occupational Employment and Wage Estimates for NAICS 324000 - Petroleum and Coal Products Manufacturing” |
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| US Bureau of Labor Statistics |
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| See: https://www.bls.gov/oes/current/naics3_324000.htm (accessed May 2, 2022). |
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| For each labor category, mean hourly wage was selected. |
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