Table 1: Annual Respondent Burden and Cost – NESHAP for Off-Site Waste and Recovery Operations (40 CFR Part 63, Subpart DD) (Renewal). |
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123.94 |
157.61 |
62.52 |
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Burden Items |
(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 (CxD) |
(F) Managerial 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. Familiarize with rule requirement c |
4 |
1 |
4 |
50 |
200 |
10 |
20 |
$27,615 |
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B. Required Activities |
See 4C |
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C. Create Information |
See 4C |
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D. Gather Existing Information |
See 4C |
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E. Write Reports |
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Initial Notification Report d |
1 |
1 |
1 |
0 |
0 |
0 |
0 |
$0 |
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Performance Test Notification Report d |
1 |
1 |
1 |
0 |
0 |
0 |
0 |
$0 |
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Compliance Status Notification d |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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Performance Test Reports d |
8 |
1 |
8 |
0 |
0 |
0 |
0 |
$0 |
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Semiannual Summary Report e |
8 |
2 |
16 |
50 |
800 |
40 |
80 |
$110,458 |
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Subtotal for Reporting Requirements |
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1,150 |
$138,073 |
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4. Recordkeeping Requirements |
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A. Familiarize with rule requirements |
See 3A |
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B. Planned Activities |
N/A |
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C. Implementation of Activities |
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a. VOHAP concentration determination |
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Commercial Facilities f |
2 |
260 |
520 |
25 |
13,000 |
650 |
1,300 |
$1,794,943 |
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Other Facilities g |
2 |
12 |
24 |
25 |
600 |
30 |
60 |
$82,844 |
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b. Vapor Pressure Determination |
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Commercial Facilities f |
1 |
260 |
260 |
25 |
6,500 |
325 |
650 |
$897,471 |
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Other Facilities g |
1 |
12 |
12 |
25 |
300 |
15 |
30 |
$41,422 |
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c. Control Equipment Visual Inspection |
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Large Cover |
0.25 |
10 |
2.5 |
50 |
125 |
6.25 |
12.5 |
$17,259 |
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Small Cover |
0.05 |
1000 |
50 |
50 |
2500 |
125 |
250 |
$345,181 |
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Closed Vent System |
0.5 |
5 |
2.5 |
50 |
125 |
6.25 |
12.5 |
$17,259 |
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d. Control Equipment Leak Monitoring |
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Cover Vented to Control Device |
1 |
5 |
5 |
50 |
250 |
12.5 |
25 |
$34,518 |
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Closed Vent System |
1 |
5 |
5 |
50 |
250 |
12.5 |
25 |
$34,518 |
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e. Control Devices |
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Continuous Monitoring System |
8 |
5 |
40 |
50 |
2,000 |
100 |
200 |
$276,145 |
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f. LDAR Program |
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Perform Monitoring/Repair |
80 |
1 |
80 |
50 |
4,000 |
200 |
400 |
$552,290 |
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g. PRD monitoring |
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Perform Monitoring/Repair |
16 |
1 |
16 |
50 |
800 |
40 |
80 |
$110,458 |
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D. Develop Record System |
N/A |
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E. Time to Enter Information |
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Control Equipment Inspections |
1 |
1 |
1 |
50 |
50 |
2.5 |
5 |
$6,904 |
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Control Equipment Monitoring |
1 |
1 |
1 |
50 |
50 |
2.5 |
5 |
$6,904 |
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Control Device CMS |
1 |
52 |
52 |
50 |
2,600 |
130 |
260 |
$358,989 |
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LDAR Program |
4 |
16 |
64 |
50 |
3,200 |
160 |
320 |
$441,832 |
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PRD Program |
2 |
16 |
32 |
50 |
1,600 |
80 |
160 |
$220,916 |
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Off-site Material Determinations |
1 |
52 |
52 |
50 |
2,600 |
130 |
260 |
$358,989 |
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F. Time to Train Personnel |
N/A |
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G. Time for Audits |
N/A |
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Subtotal for Recordkeeping Requirements |
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46,633 |
$5,598,840 |
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TOTAL ANNUAL BURDEN AND COSTS (rounded): h |
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47,800 |
$5,740,000 |
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478 |
hr per resp |
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TOTAL CAPITAL AND O&M COST: h |
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$908,000 |
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GRAND TOTAL: h |
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$6,650,000 |
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Assumptions: |
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a We have assumed that there are approximately 50 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three years. |
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b This ICR uses the following labor rates: Managerial $157.61 ($75.05 + 110%); Technical $123.94 ($59.02 + 110%); and Clerical $62.52 ($29.77 + 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2021, “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 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 It is assumed that it will take 4 hours to read instructions. |
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d It is assumed that there will be no new sources. |
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e The burden of one annual summary report was included in the burden estimate for the semiannual report. |
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f It is assumed that 50 percent of the facilities, the owner or operator manages, for a fee, off-site materials received from other generators. |
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g It is assumed that 50 percent of the owners or operators accept the off-site material at another location and ship it to the facility for storage, treatment, or disposal. |
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h 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 Off-Site Waste and Recovery Operations (40 CFR Part 63, Subpart DD) (Renewal). |
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52.37 |
70.56 |
28.34 |
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Activity |
(A) EPA Hours/ Occurrence |
(B) Occurrences/ Plant/ Year |
(C) EPA Hours/ Year (AxB) |
(D) Plants/ Year a |
(E) Technical Hours/ Year (CxD) |
(F) Managerial Hours/ Year (Ex0.05) |
(G) Clerical Hours/ Year (Ex0.1) |
(H) Costs, $ b |
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Report Review |
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New Plants c, d |
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Initial notification (PRD) |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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Performance test notification |
1 |
1 |
1 |
0 |
0 |
0 |
0 |
$0 |
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Compliance status notification |
4 |
1 |
4 |
0 |
0 |
0 |
0 |
$0 |
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Performance test report e |
16 |
1 |
16 |
0 |
0 |
0 |
0 |
$0 |
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Existing Plants |
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Startup/shutdown report |
N/A |
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Semiannual summary report f |
4 |
2 |
8 |
50 |
400 |
20 |
40 |
$23,493 |
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TOTAL ANNUAL BURDEN AND COST (rounded) g |
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460 |
$23,500 |
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Assumptions: |
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a We have assumed that there are approximately 50 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three years. |
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b This ICR uses the following labor rates: Managerial $70.56 (GS-13, Step 5, $44.10 + 60%); Technical $52.37 (GS-12, Step 1, $32.73 + 60%); and Clerical $28.34 (GS-6, Step 3, $17.71 + 60%). These rates are from the Office of Personnel Management (OPM), 2022 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 There will be no travel expenses associated with this ICR since we have assumed that no new sources will become subject to this rule over the three year period of this ICR. |
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d It is assumed that there will be no new sources over the three year period of this ICR. |
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e It is assumed that it will take 16 hours to review each performance test report. |
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f It is assumed that each facility will take 4 hours twice a year to submit report. |
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g Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
Capital/Startup vs. Operation and Maintenance (O&M) Costs |
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(A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
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Continuous Monitoring Device |
Capital/Startup Cost for One Respondent |
Number of New Respondents |
Total Capital/Startup Cost, (B X C) |
Annual O&M Costs for One Respondent |
Number of Respondents with O&M |
Total O&M, (E X F) |
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O&M a |
$0 |
0 |
$0 |
$1,878 |
50 |
$93,900 |
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LDAR |
$41,254 |
0 |
$0 |
$11,876 |
50 |
$593,800 |
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PRD Monitoring Equipment b |
$27,000 |
0 |
$0 |
$4,000 |
50 |
$200,000 |
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Storage Tanks Duct Work c |
$76,412 |
0 |
$0 |
$20,797 |
1 |
$20,797 |
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Totals (rounded) d |
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$0 |
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$908,000 |
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$908,000 |
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a The 2014 proposal ICR (1717.10) states "Based on a previous ICR for the Pesticide Active Ingredient source category, which estimated the annual O&M costs to be $1,450 per source in 2011 dollars, inflating this number from 2011 dollars to 2013 dollars gives $1,505 per source." These are the ongoing costs to maintain the monitor and other costs such as photocopying and postage. These costs have been adjusted from 2013 dollars to 2021 dollars. |
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b Reflects updated costs for PRD monitoring for stationary sources from the January 29, 2018 final rule (83 FR 3986). The annualized costs per facility (assuming a 15-year equipment life and a seven percent interest rate) are estimated to be approximately $4,000. See memorandum from Carey, A., EPA, “Pressure Relief Device Control Options and Impacts for Off-Site Waste and Recovery Operations (OSWRO) June 26, 2017”, Docket Id. No. EPA-HQ-OAR-2012-0360-0133. |
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c Costs shown are the total costs for the estimated 21 additional tanks captured under the new 2015 threshold from the March 2015 final rule. |
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d Totals have been rounded to 3 significant digits. Figures may not add exactly due to rounding. |
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