ICR Summary Information | |
Hours Per Response | 22 |
Number of Respondents | 2900 |
Total Estimated Burden Hours | 67,700 |
Total Estimated Costs | $9,270,000 |
Annualized Capital O&M | Not Applicable |
Form Number | Not Applicable |
Table 1: Annual Respondent Burden and Cost - NESHAP for Plating and Polishing Operations (40 CFR Part 63, Subpart WWWWWW) (Renewal) | ||||||||||||
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) | Total Cost Per year b |
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1. Applications | N/A | |||||||||||
2. Surveys and Studies | N/A | |||||||||||
3. Acquisition, Installation, and Utilization of Technology and Systems | N/A | |||||||||||
4. Reporting Requirements | ||||||||||||
A. Familiarization with Regulatory Requirements c | 1 | 1 | 1 | 2,900 | 2,900 | 145 | 290 | $456,768.85 | ||||
B. Required activities | Labor Rates | |||||||||||
Initial Notification of applicability d | 2 | 1 | 2 | 0 | 0 | 0 | 0 | $0 | Technical | $141.75 | ||
Notification of Compliance Status e | 4 | 1 | 4 | 0 | 0 | 0 | 0 | $0 | Management | $172.41 | ||
Annual Compliance Certification f | 2 | 1 | 2 | 2,900 | 5,800 | 290 | 580 | $913,537.70 | Clerical | $71.36 | ||
Annual Report of Deviations g | 2 | 1 | 2 | 145 | 290 | 14.5 | 29 | $45,676.89 | ||||
C. Create information | See 4B | |||||||||||
D. Gather existing information | See 4B | |||||||||||
E. Write report | See 4B | |||||||||||
Reporting Subtotal | 10,339 | $1,415,983 | ||||||||||
5. Recordkeeping Requirements | ||||||||||||
A. Familiarization with Regulatory Requirements | See 4A | |||||||||||
B. Plan activities | See 5E | |||||||||||
C. Implement activities | See 5E | |||||||||||
D. Develop record system | See 5E | |||||||||||
E. Time to enter information | N/A | |||||||||||
Records of all information required by standards h | 0.33 | 52 | 17.16 | 2,900 | 49,764 | 2,488.2 | 4,976.4 | $7,838,153.47 | ||||
F. Time to train personnel | N/A | |||||||||||
G. Time to adjust existing ways to comply with previously applicable requirements | N/A | |||||||||||
H. Time to transmit or disclose information i | 0.25 | 1 | 0.25 | 290 | 72.5 | 3.63 | 7.25 | $11,419.22 | ||||
I. Time for audits | N/A | |||||||||||
Recordkeeping Subtotal | 57,312 | $7,849,572.69 | ||||||||||
TOTAL LABOR BURDEN AND COST (rounded)j | 67,700 | $9,270,000 | ||||||||||
TOTAL CAPITAL AND O&M COST (rounded)j | $0 | |||||||||||
GRAND TOTAL (rounded)j | $9,270,000 | |||||||||||
22 | hours per response | |||||||||||
Assumptions | ||||||||||||
a There are an estimated 2,900 existing plating and polishing plants and no new facilities are expected. | ||||||||||||
b This ICR uses the following labor rates: Managerial $172.41 ($82.10+ 110%); Technical $141.75 ($67.50 + 110%); and Clerical $71.36 ($33.98 + 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, December 2023, “Table 2. Civilian workers by occupational and industry group.” The rates are from column 1, “Total compensation.” The rates are increased by 110 percent to account for varying industry wage rates and the additional overhead business costs of employing workers beyond their wages and benefits, including business expenses associated with hiring, training, and equipping their employees. | ||||||||||||
c We assume that each source subject to the standard will have to familiarize with the regulatory requirements each year. | ||||||||||||
d Each of the 2,900 existing plants noted above would have already submitted an initial notification. Since there are no new facilities expected, the number of respondents required to submit an initial notification is 0. | ||||||||||||
e Each of the 2,900 existing plants noted above would have already submitted a notification of compliance status by the appropriate compliance date. Since there are no new facilities expected, the number of respondents required to submit a notification of compliance status is 0. | ||||||||||||
f The 2,900 existing plants would be required to prepare an annual compliance certification every year. They would only submit the certifications if a deviation occurred; assuming that 5 percent of the plants experience a deviation, the number of compliance certifications submitted will be (2,900*0.05) = 145. | ||||||||||||
g Assumes that 5% of existing facilities would have to submit a report of deviations starting in Year 3 of the ICR clearance period, or (2,900 * 0.05) = 145 facilities. | ||||||||||||
h It is assumed that 0.33 hr (20 minutes) per week will be required per facility for recordkeeping. | ||||||||||||
i Annual transmittals would include submission of annual compliance certifications (145) and reports of deviations (145) for 5% of one-third of 2,900 facilities, so (2,900* 0.05) *2 = 145 *2 = 290 respondents. | ||||||||||||
j Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
Table 2: Average Annual EPA Burden and Cost - NESHAP for Plating and Polishing Operations (40 CFR Part 63, Subpart WWWWWW) (Renewal) | |||||||||||
Activity | (A) | (B) | (C) | (D) | (E) | (F) | (G) | (H) | |||
EPA Person-hours per occurrence | No. of occurrences per respondent per year | EPA Person-hours per plant per year (A) x (B) |
Plants per year | Technical person-hours (C) x (D) |
Managerial person-hours (E) x 0.05 |
Clerical person-hours (E) x 0.10 |
Cost, $ a | ||||
Report Review: | Labor Rates | ||||||||||
Initial Notification of applicability b | 1 | 1 | 1 | 0 | 0 | 0 | 0 | $0 | Technical | $57.07 | |
Notification of Compliance Status c | 2 | 1 | 2 | 0 | 0 | 0 | 0 | $0 | Management | $76.91 | |
Annual Compliance Certification d | 2 | 1 | 2 | 145 | 290 | 14.5 | 29 | $18,561.02 | Clerical | $30.88 | |
Annual Report of Deviations e | 2 | 1 | 2 | 145 | 290 | 14.5 | 29 | $18,561.02 | |||
TOTAL ANNUAL BURDEN AND COST (rounded)f | 667 | $37,100 | |||||||||
Assumptions | |||||||||||
a This cost is based on the average hourly labor rate as follows: Managerial $76.91 (GS-13, Step 5, $48.07 + 60%); Technical $57.07 (GS-12, Step 1, $35.67 + 60%); and Clerical $30.88 (GS-6, Step 3, $19.30+ 60%). This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. These rates are from the Office of Personnel Management (OPM), 2024 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. | |||||||||||
b Assumes no new plants in the next three years. | |||||||||||
c Each of the 2,900 existing plants noted above would have already submitted a notification of compliance status by the appropriate compliance date. Since there are no new facilities expected, the number of respondents required to submit a notification of compliance status is 0. | |||||||||||
d The 2,900 existing plants would be required to prepare an annual compliance certification; any plant that experiences a deviation will have to submit the compliance certification; assuming 5 percent of the plants experience a deviation during the three year ICR period, the number of submittals would be (2,900 * 0.05) =145. | |||||||||||
e Assumes that 5% of existing facilities would have to submit a report of deviations in the three-year ICR period, or (2,900 * 0.05) = 145. | |||||||||||
f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
Estimating Capital/Startup and Operation and Maintenance Costs | |||||||||
The only costs to the regulated industry resulting from information collection activities required by the subject standards are labor costs. There are no capital/startup or operation and maintenance costs. |
Total Annual Responses | ||||
(A) | (B) | (C) | (D) | (E) |
Information Collection Activity | Number of Respondents | Number of Responses | Number of Existing Respondents That Keep Records But Do Not Submit Reports | Total Annual Responses E=(BxC)+D |
Initial Notification of Applicability | 0 | 1 | N/A | 0 |
Notification of Compliance Status | 0 | 1 | N/A | 0 |
Annual Compliance Certification | 145 | 1 | 2755 | 2900 |
Annual Report of Deviations | 145 | 1 | N/A | 145 |
Total | 3045 |
Number of Respondents | |||||
Respondents That Submit Reports | Respondents That Do Not Submit Any Reports | ||||
(A) | (B) | (C) | (D) | (E) | |
Year | Number of New Respondents 1 a | Number of Existing Respondents | Number of Existing Respondents that keep records but do not submit reports | Number of Existing Respondents That Are Also New Respondents | Number of Respondents (E=A+B+C-D) |
1 | 0 | 145 | 2755 | 0 | 2900 |
2 | 0 | 145 | 2755 | 0 | 2900 |
3 | 0 | 145 | 2755 | 0 | 2900 |
Average | 0 | 145 | 2755 | 0 | 2900 |
1 a New respondents include sources with constructed, reconstructed and modified affected facilities. |
File Type | application/vnd.openxmlformats-officedocument.spreadsheetml.sheet |
File Modified | 0000-00-00 |
File Created | 0000-00-00 |