|
|
|
|
|
106.45 |
138.43 |
52.77 |
|
|
|
|
Burden Items |
(A) Person hours per occurrence |
(B) Occurrences per respondent per year |
(C) Person hours per respondent per year (AxB) |
(D) Respondents per year a |
(E) Technical person hours per year (CxD) |
(F) Managerial person hours per year (Ex0.05) |
(G) Clerical person hours per year (Ex0.1) |
(H) Total Cost per year, $ b |
|
|
|
1. Applications |
N/A |
|
|
|
|
|
|
|
|
|
|
2. Survey and Studies |
N/A |
|
|
|
|
|
|
|
|
|
|
3. Reporting Requirements |
|
|
|
|
|
|
|
|
|
|
|
A. Familiarization with the regulatory requirements c |
4 |
1 |
4 |
8 |
32 |
1.6 |
3.2 |
$3,796.75 |
|
|
|
B. Required Activities |
|
|
|
|
|
|
|
|
|
|
|
Initial performance test d |
421 |
1 |
421 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
Repeat performance test d, e |
421 |
0.2 |
84.2 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
Operations, maintenance, and monitoring plan f |
40 |
1 |
40 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
Startup, shutdown, and malfunction plan g |
40 |
1 |
40 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
COS Testing q |
|
|
|
8 |
|
|
|
$34,400 |
|
|
|
HCl/HF Testing q |
|
|
|
8 |
|
|
|
$10,400 |
|
|
|
Phenol and methanol testing q |
|
|
|
8 |
|
|
|
$14,400 |
|
|
|
C. Create Information |
See 3B |
|
|
|
|
|
|
|
|
|
|
D. Gather Existing Information |
See 3B |
|
|
|
|
|
|
|
|
|
|
E. Write Reports |
|
|
|
|
|
|
|
|
|
|
|
Notification of applicability h |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
Notification of construction/ reconstruction h |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
Notification of actual startup h |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
Notification of special compliance requirements h |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
Notification of initial performance test h |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
Notification of compliance status h |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
Request for extension of compliance adjustment to time periods, and changes in information h |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
Report of performance test |
See 3B |
|
|
|
|
|
|
|
|
|
|
Excess emissions report i |
16 |
2 |
32 |
1.6 |
51.2 |
2.56 |
5.12 |
$6,074.80 |
|
|
|
Report of no excess emission j |
8 |
2 |
16 |
6.4 |
102.4 |
5.12 |
10.24 |
$12,149.61 |
|
|
|
Quality improvement plan k |
40 |
1 |
40 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
Startup, shutdown, and malfunction report l |
8 |
2 |
16 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
Subtotal for Reporting |
|
|
|
|
213 |
$81,221.16 |
|
|
|
4. Recordkeeping Requirements |
|
|
|
|
|
|
|
|
|
|
|
A. Familiarization with the regulatory requirements |
See 3A |
|
|
|
|
|
|
|
|
|
|
B. Plan Activities |
See 3E |
|
|
|
|
|
|
|
|
|
|
C. Implement Activities |
See 3E |
|
|
|
|
|
|
|
|
|
|
D. Develop Record System |
See 3E |
|
|
|
|
|
|
|
|
|
|
E. Time to Enter Information |
|
|
|
|
|
|
|
|
|
|
|
Records of operating parameters and emissions n |
4 |
52 |
208 |
8 |
1664 |
83.2 |
166.4 |
$197,431.10 |
|
|
|
F. Time to transmit or disclose information o |
0.25 |
2 |
0.5 |
8 |
4 |
0.2 |
0.4 |
$474.59 |
|
|
|
G. Time to Train Personnel |
N/A |
|
|
|
|
|
|
|
|
|
|
H. Time for Audits |
N/A |
|
|
|
|
|
|
|
|
|
|
Subtotal for Recordkeeping |
|
|
|
|
1,918 |
$197,905.70 |
|
|
|
Total Labor Burden and Cost (rounded) p |
|
|
|
|
2,130 |
$279,000 |
|
133 |
hr per resp |
Capital and O&M Cost (see Section 6(b)(iii)): p |
|
|
|
|
|
|
|
$6,000 |
|
|
|
TOTAL COST: p |
|
|
|
|
|
|
|
$285,000 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Assumptions: |
|
|
|
|
|
|
|
|
|
|
|
a We have assumed that the average number of respondents potentially subject to this rule is 8. There will be no additional new sources over the three-year period of this ICR. |
|
|
|
b This ICR uses the following labor rates: $138.43 for Managerial, $106.45 for Technical, and $52.77 for Clerical. |
|
|
|
c We have assumed that it will take each respondent 4 hours to familiarize with the regulatory requirements. |
|
|
|
d We have assumed that it will take 421 hours for each respondent to complete performance test based on the following: (1.7 sources per plant x 130 hours per source +200 hours for calibration, retesting, sample analysis, etc) for a total of 421 hours. |
|
|
|
e We have assumed that 20% of respondents will have to repeat performance test due to failure. |
|
|
|
f We have assumed that each of the respondents will take 40 hours to prepare the operation, maintenance, and monitoring plan. |
|
|
|
g We have assumed that each of the respondents will take 40 hours to prepare the startup, shutdown, and malfunction plan. |
|
|
|
h We have assumed that each of the respondents will take 2 hours to write reports. |
|
|
|
i We have assumed that 20% of respondents will each take 16 hours two times per year to write excess emission reports. |
|
|
|
j We have assumed that 80% of respondents will take 8 hours two times per year to complete the report for no excess emissions. |
|
|
|
k We have assumed that 10% of facilities are required to prepare a quality improvement plan each year. |
|
|
|
l We have assumed that each respondent will take 8 hours two times per year to complete a startup, shutdown, and malfunction report. |
|
|
|
m We have assumed that the respondents will each take 4 hours to familiarize with the regulatory requirements. |
|
|
|
n We have assumed that each respondent will take 4 hours 52 times per year to enter information. |
|
|
|
o We have assumed that it will take each respondent 15 minutes (0.25 hours) two times per year to transmit of disclose information. |
|
|
|
p Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
|
|
|
q We estimate annualized compliance testing cost will cost $59,200 for all 8 facilities ($34,400 for COS test, $10,400 for HCl/HF test, and $14,400 for phenol/methanol test). See EPA-HQ-OAR-2010-1041-0171.pdf |
|
|
|
|
|
|
|
|
47.62 |
64.16 |
25.76 |
|
Activity |
(A) EPA Hours per occurrence |
(B) Number of occurrences per Year |
(C) EPA Hours per Year (AxB) |
(D) Plants per Year a |
(E) Technical Hours per Year (CxD) |
(F) Managerial Hours per Year (Ex0.05) |
(G) Clerical Hours per Year (Ex0.10) |
(H) Total cost per year, $ b |
Initial performance tests |
|
|
|
|
|
|
|
|
New or modified facility |
40 |
1 |
40 |
0 |
0 |
0 |
0 |
$0 |
Repeat performance tests |
|
|
|
|
|
|
|
|
A. Familiarization with the regulatory requirements c |
40 |
0.2 |
8 |
0 |
0 |
0 |
0 |
$0 |
Report review |
|
|
|
|
|
|
|
|
Notification of applicability |
2 |
1 |
|
0 |
|
|
|
|
Notification of construction/ reconstruction |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
Notification of actual startup |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
Notification of special compliance requirements |
1 |
1 |
1 |
0 |
0 |
0 |
0 |
$0 |
Notification of initial performance test |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
Notification of compliance status |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
Request for extension of compliance, adjustment to time periods, and changes in information |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
Quality improvement plan d |
40 |
1 |
40 |
0 |
0 |
0 |
0 |
$0 |
Operations, maintenance, and monitoring plan |
40 |
1 |
40 |
0 |
0 |
0 |
0 |
$0 |
Startup, shutdown, and malfunction plan e |
40 |
1 |
40 |
0 |
0 |
0 |
0 |
$0 |
Report of performance test |
40 |
1 |
40 |
0 |
0 |
0 |
0 |
$0 |
Excess emissions report f |
20 |
2 |
40 |
1.6 |
64 |
3.2 |
6.4 |
$3,417.86 |
Report of no excess emissions g |
2 |
2 |
4 |
6.4 |
25.6 |
1.28 |
2.56 |
$1,367.14 |
Startup, shutdown, and malfunction report h |
20 |
2 |
40 |
8 |
320 |
16 |
32 |
$17,089.28 |
Review compliance test reports for COS for cupolas and formaldehyde, phenol, and methanol for collection/curing operations i |
8 |
1 |
8 |
8 |
64 |
3.2 |
6.4 |
$3,417.86 |
Total Labor Burden and Cost (rounded) j |
|
|
|
|
545 |
$25,300 |
|
|
|
|
|
|
|
|
|
Assumptions: |
|
|
|
|
|
|
|
|
a We have assumed that the average number of respondents potentially subject to this rule is 8. There will be no additional new sources over the three-year period of this ICR. |
|
|
|
|
|
|
|
|
b This ICR uses the following labor rates: $64.16 for Managerial, $47.62 for Technical, and $25.76 for Clerical. |
|
|
|
|
|
|
|
|
c We have assumed that 20% of respondents will fail the performance test. |
|
|
|
|
|
|
|
|
d We have assumed that it will take 40 hours for each respondent to review the quality improvement plan report. |
|
|
|
|
|
|
|
|
e We have assumed that it will take 40 hours for each respondent to review the startup, shutdown, and malfunction plan. |
|
|
|
|
|
|
|
|
f We have assumed that 20% of respondents will take 20 hours to review the excess emissions report. |
|
|
|
|
|
|
|
|
g We have assumed that 80% of respondents will take 2 hours to review the report of no excess emissions. |
|
|
|
|
|
|
|
|
h We have assumed that each respondent will take 20 hours to review the startup, shutdown, malfunction report. |
|
|
|
|
|
|
|
|
i Assumes Agency will review all of the annual reports - including the new COS, phenol, and methanol emissions testing. |
|
|
|
|
|
|
|
|
j Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
|
|
|
|
|
|
|
|