| Table 1: Annual Respondent Burden and Cost – NSPS for Pressure Sensitive Tape and Label Surface Coating Operations (40 CFR Part 60, Subpart RR) (Renewal) |
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$117.92 |
$147.40 |
$57.02 |
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| Burden item |
(A) Person-hours per occurrence |
(B) No. of occurrences per respondent per year |
(C) Person-hours per respondent per year (C=AxB) |
(D) Respondents per year a |
(E) Technical person-hours per year (E=CxD) |
(F) Management person-hours per year (Ex0.05) |
(G) Clerical person-hours per year (Ex0.1) |
(H) Total costs per Year b |
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| 1. Applications |
N/A |
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| 2. Survey and Studies |
N/A |
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| 3. Reporting Requirements |
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| A. Familiarization with the regulatory requirements c |
0.87 |
1 |
0.87 |
45 |
39.15 |
1.96 |
3.92 |
$5,128.34 |
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| B. Required activities |
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| Initial performance test |
52.17 |
1 |
52.17 |
1 |
52.17 |
2.61 |
5.22 |
$6,833.85 |
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| Repeat performance test d |
52.17 |
1 |
52.17 |
0.2 |
10.43 |
0.52 |
1.04 |
$1,366.77 |
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| C. Create information |
See 3B |
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| D. Gather existing information |
See 3E |
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| E. Write report |
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| Notification of construction/reconstruction |
1.74 |
1 |
1.74 |
1 |
1.74 |
0.09 |
0.17 |
$227.93 |
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| Notification of actual startup |
1.74 |
1 |
1.74 |
1 |
1.74 |
0.09 |
0.17 |
$227.93 |
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| Notification of initial performance test |
1.74 |
1 |
1.74 |
1 |
1.74 |
0.09 |
0.17 |
$227.93 |
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| Report of performance test |
See 3B |
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| Excess emission reports |
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| VOC emission reports e |
4.35 |
2 |
8.7 |
45 |
391.5 |
19.58 |
39.15 |
$51,283.37 |
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| Temperature reports f |
3.48 |
2 |
6.96 |
36 |
250.56 |
12.53 |
25.06 |
$32,821.36 |
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| Subtotal for Reporting Requirements |
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861 |
$98,117.46 |
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| 4. Recordkeeping Requirements |
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| A. Familiarization with the regulatory requirements |
See 3A |
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| B. Plan activities |
See 4C |
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| C. Implement activities |
See 3B |
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| Monthly performance test g |
0.87 |
12 |
10.44 |
45 |
469.8 |
23.49 |
46.98 |
$61,540.04 |
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| D. Develop record system |
N/A |
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| D. Develop record system |
N/A |
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| E. Time to enter information |
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| Records of operating parameters h |
0.22 |
250 |
55 |
45 |
2,475 |
123.75 |
247.5 |
$324,205.20 |
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| F. Train personnel |
N/A |
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| G. Audits |
N/A |
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| Subtotal for Recordkeeping Requirements |
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3,387 |
$385,745.24 |
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| TOTAL LABOR BURDEN AND COST (rounded) i |
4,250 |
$484,000 |
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| TOTAL CAPITAL AND O&M COSTS (rounded)i |
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$88,000 |
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| GRAND TOTAL (rounded): i |
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$572,000 |
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26 |
hr/resp* |
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| Assumptions: |
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| a We have assumed that the average number of respondents potentially subject to this rule is 45. There will be one additional new source per year over the three-year period of this ICR. |
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| b This ICR uses the following labor rates: $147.40 per hour for Executive, Administrative, and Managerial labor; $117.92 per hour for Technical labor, and $57.02 |
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| per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2018, Table 2. Civilian Workers, by occupational and industry group. The rates are from column 1, Total compensation. The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry. |
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| c We have assumed that it will take 0.87 hours for a new respondent to read instructions. |
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| d We have assumed that 20 percent of respondents will have to repeat performance tests because of failure. |
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| e We have assumed that each source submits one excess emission report every year, in addition to the required semiannual report. |
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| f We have assumed that 80 percent of sources will use incineration to control emissions. |
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| g We assume that each respondent will take 0.87 hours once per month to record performance test. |
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| h We assume that each respondent will take 0.22 hours 250 time per year to record operating parameters. |
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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 – NSPS for Pressure Sensitive Tape and Label Surface Coating Operations (40 CFR Part 60, Subpart RR) (Renewal) |
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48.75 |
65.71 |
26.38 |
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| Activity |
(A) EPA person-hours per occurrence |
(B) No. of occurrences per plant per year |
(C) EPA person-hours per plant per year (C=AxB) |
(D) Plants per Year a |
(E) Technical person-hours per year (E=CxD) |
(F) Management person-hours per year (Ex0.05) |
(G) Clerical person-hours per year (Ex0.1) |
(H) Total Cost, $ b |
| New facility |
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| Initial performance test |
20.87 |
1 |
20.87 |
1 |
20.87 |
1.04 |
2.09 |
$1,141.04 |
| Repeat performance test/observed |
20.87 |
1 |
20.87 |
0.2 |
4.17 |
0.21 |
0.42 |
$228.21 |
| Review reports c |
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| Notification of construction |
1.74 |
1 |
1.74 |
1 |
1.74 |
0.09 |
0.17 |
$95.13 |
| Notification of initial startup |
0.43 |
1 |
0.43 |
1 |
0.43 |
0.02 |
0.04 |
$23.51 |
| Notification of actual startup |
0.43 |
1 |
0.43 |
1 |
0.43 |
0.02 |
0.04 |
$23.51 |
| Notification of initial performance test |
0.43 |
1 |
0.43 |
1 |
0.43 |
0.02 |
0.04 |
$23.51 |
| Review test results |
6.96 |
1 |
6.96 |
1 |
6.96 |
0.35 |
0.70 |
$380.53 |
| Existing Plant |
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| VOC emission reports d |
1.74 |
2 |
3.48 |
45 |
156.60 |
7.83 |
15.66 |
$8,561.87 |
| Temperature reports e, f |
1.74 |
2 |
3.48 |
36 |
125.28 |
6.26 |
12.53 |
$6,849.50 |
| TOTAL ANNUAL LABOR BURDEN AND COSTS (rounded) g |
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364 |
$17,300 |
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| Assumptions: |
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| a We have assumed that the average number of respondents potentially subject to this rule is 45. There will be one additional new source per year over the three-year period of this ICR. |
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| b Labor rates for Federal agency personnel were applied to State/Local agencies, and are based on the average hourly labor rate as follows: Technical $48.75 (GS-12, Step 1, $30.47 + 60%); |
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| Managerial $65.71 (GS-13, Step 5, $41.07 + 60%); and Clerical $26.38 (GS-6, Step 3, $26.38 + 60%). This ICR assumes that |
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| Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. These rates are from the OPM, 2018 General Schedule, |
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| which excludes locality rates of pay. The rates have been applied to local agencies and have been increased by 60 percent to account for the benefit packages |
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| available to government employees. |
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| c We assume that each of the new facilities will submit initial notifications. |
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| d We assume that each source submits one excess emission report every year, in addition to the required semiannual report. |
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| e We assume that 80 percent of sources use incineration. |
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| f We assume that temperature reports are conducted two times per year. |
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| g Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
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