| Table 1: Annual Respondent Burden and Cost - NESHAP for Nine Metal Fabrication and Finishing Area Sources (40 CFR Part 63, Subpart XXXXXX) (Renewal) |
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(A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
(H) |
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| Burden Item |
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) |
Managerial person-hours per year (E x 0.05) |
Clerical person-hours per year (E x 0.10) |
Total Cost, $ b |
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| 1. Applications |
N/A |
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$141.75 |
Technical |
| 2. Surveys and Studies |
N/A |
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$172.41 |
Managerial |
| 3. Acquisition, Installation, and Utilization of Technology and Systems |
N/A |
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$71.36 |
Clerical |
| 4. Reporting Requirements |
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| A. Familiarize with regulatory requirements d |
0.5 |
1 |
0.5 |
5,800 |
2,900 |
145 |
290 |
$456,768.85 |
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| B. Required activities |
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| Initial notification c |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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| Notification of compliance status c, e |
4 |
1 |
4 |
0 |
0 |
0 |
0 |
$0 |
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| Annual compliance certification f |
2 |
1 |
2 |
5,800 |
11,600 |
580 |
1,160 |
$1,827,075.40 |
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| Report of exceedances g |
2 |
1 |
2 |
290 |
580 |
29 |
58 |
$91,353.77 |
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| C. Create information |
See 4B |
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| D. Gather existing information |
See 4B |
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| E. Write report |
See 4B |
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| Subtotal for Reporting Requirements |
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17,342 |
$2,375,198.02 |
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| 5. Recordkeeping Requirements |
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| A. Familiarize with regulatory requirements |
See 4A |
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| B. Plan activities |
See 5E |
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| C. Implement activities |
See 5E |
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| D. Develop record system |
See 5E |
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| E. Time to enter information |
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| Records of all information required by standards h |
0.25 |
12 |
3 |
5,800 |
17,400 |
870 |
1740 |
$2,740,613.10 |
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| F. Time to train personnel |
N/A |
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| G. Time to adjust existing ways to comply with previously applicable requirements |
N/A |
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| H. Time to transmit or disclose information i |
0.25 |
1 |
0.25 |
5,800 |
1,450 |
72.5 |
145 |
$228,384.43 |
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| I. Time for audits |
N/A |
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| Subtotal for Recordkeeping Requirement |
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21,678 |
$2,968,997.53 |
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| TOTAL LABOR BURDEN AND COST (rounded)j |
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39,000 |
$5,340,000 |
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| TOTAL CAPITAL & O&M COST (rounded) j |
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$0 |
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| GRAND TOTAL (rounded) j |
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$5,340,000 |
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| Assumptions: |
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6 |
hr per resp |
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| a There are an estimated 5,800 existing metal fabrication and finishing facilities subject to the rule with no new facilities expected. |
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| 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. |
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| c One-time notification. |
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| d We have assumed that each respondent will each take 0.5 hours to familiarize with regulatory requirements. |
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| e We have assumed that each respondent will take four hours to complete the notification of compliance status task. |
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| f We have assumed that each respondent will take two hours once per year to complete the task. |
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| g Percentage of respondents with exceedances is assumed to be 5%. |
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| h We have assumed that each respondent will take 0.25 hours once per month to record information that are required by the standards. |
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| i We have assumed that each respondent will take 0.25 hours once per year to transmit or disclose information. |
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| j 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 Nine Metal Fabrication and Finishing Area Sources (40 CFR Part 63, Subpart XXXXXX) (Renewal) |
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| Activity |
(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 (C=AxB) |
Respondents per year a |
Technical person-hours (E=CxD) |
Managerial person-hours (Ex0.05) |
Clerical person-hours (Ex0.1) |
Cost, $ b |
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| Report Review: |
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| Initial Notification c |
1 |
1 |
1 |
0 |
0 |
0 |
0 |
$0 |
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$57.07 |
| Notification of compliance status c |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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$76.91 |
| Annual Certification/ Compliance Report d |
2 |
1 |
2 |
5,800 |
11,600 |
580 |
1,160 |
$742,440.60 |
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$30.88 |
| Report of exceedances d,e |
2 |
1 |
2 |
290 |
580 |
29 |
58 |
$37,122.03 |
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| TOTAL (rounded)f |
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14,000 |
$780,000 |
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| Assumptions: |
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| a There are an estimated 5,800 existing metal fabrication and finishing facilities subject to the rule with no new facilities expected. |
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| b 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. |
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| c One-time notification. |
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| d We have assumed two hours once per year to review reports. |
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| e Percentage of respondents with exceedances is assumed to be 5%. |
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| f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
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| Number of Respondents |
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Respondents That Submit Reports |
Respondents That Do Not Submit Any Reports |
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(A) |
(B) |
(C) |
(D) |
(E) |
| Year |
Number of New Respondents 1 |
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 |
5,800 |
0 |
0 |
5,800 |
| 2 |
0 |
5,800 |
0 |
0 |
5,800 |
| 3 |
0 |
5,800 |
0 |
0 |
5,800 |
| Average |
0 |
5,800 |
0 |
0 |
5,800 |
| 1 New respondents include sources with constructed, reconstructed and modified affected facilities. |