Calculation Tables for ICR 2177.06

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Overview

Table 1
Table 2

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Sheet 1: Table 1

Table 1: Annual Respondent Burden and Cost – NSPS for Stationary Combustion Turbines (40 CFR Part 60, Subpart KKKK) (Renewal)
					103.97	129.93	51.79
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 (F=Ex0.05)	(G) Clerical person hours per year (G=Ex0.1)	(H) Total Cost per year, $ b
1. Applications	N/A
2. Surveys and studies	N/A
3. Reporting requirements
A. Familiarization with Regulatory Requirements c	4	1	4	589	2,356	117.8	235.6	$272,460.80
B. Required activities
- Performance test d	12	1	12	199	2,388	119.4	238.8	$276,161.45
- Fuel sampling – dual fuel turbines e	0.5	52	26	106	2,756	137.8	275.6	$318,719
- Fuel sampling – distillate oil only turbines f	0.5	5	2.5	7	17.5	0.88	1.75	$2,023.80
C. Gather existing information	See 3D
D. Write report
Notification of construction/ reconstruction g, h	2	1	2	47	94	4.7	9.4	$10,870.68
Notification of actual startup g, h	2	1	2	47	94	4.7	9.4	$10,870.68
Notification of performance test g	2	1	2	199	398	19.9	39.8	$46,026.91
Notification of demonstration of CEMS i	2	1	2	15	30	1.5	3	$3,469.37
Initial notification of compliance g, h	2	1	2	47	94	4.7	9.4	$10,870.68
Compliance report j, k	8	2	16	542	8,672	433.6	867.2	$1,002,877.78
Subtotal for Reporting Requirements					19,434			$1,954,351
4. Recordkeeping requirements
A. Familiarization with Regulatory Requirement c	See 3A
B. Train personnel h	40	1	40	47	1,880	94	188	$217,413.54
C. Continuous monitoring
- Record information k, l	5	12	60	542	32,520	1,626	3,252	$3,760,791.66
Subtotal for Recordkeeping Requirements					39,560			$3,978,205
TOTAL LABOR BURDEN AND COST (rounded)m					59,000			$5,930,000
Captial and O&M Cost								$0
Grand Total								$5,930,000			41	hr/response
Assumptions:
a We have assumed that there is an average of 542 sources currently subject to the regulations and an additional 47 respondents per year will become subject. It was established that there will be about 355 new stationary combustion turbines installed in the United States over the first five years of rule implementation. The ICR for the initial rule assumed 71 new sources for the first three years, and the most recent ICR assumed a growth of 47 new sources per year. This ICR assumes the industry continues to grow at a constant rate since the previous renewal.
b This ICR uses the following labor rates: $129.93 per hour for Executive, Administrative, and Managerial labor; $103.97 per hour for Technical labor, and $51.79 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2014, 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.
c We have assumed that it will take 4 hours for respondents to familiarize with regulatory requirements and that all sources will have to familiarize with requlatory requirements.
d We have assumed that 199 respondents will each take 12 hours to conduct annual stack testing to demonstrate compliance with NOx emission limitation.
e We have assumed that 106 respondents will each take 0.5 hours at 52 times per year to complete fuel sampling for the dual fuel turbines.
f We have assumed that seven respondent will each take 0.5 hours 5 times per year to complete the fuel sampling for the distillate oil only turbines.
g We have assumed that it will take each respondent 2 hours to write notification report.
h We have assumed that this is a one-time report for new respondents.
i We have assumed that of the 47 new respondents each year, 15 of these respondents will write reports demonstrating CEMS compliance.
j We have assumed that each of the respondents will take 8 hours twice per year to write the compliance report.
k The average number of existing respondents is 542.
l We have assumed that it will take each respondent 5 hours twelve times per year to record information.
m Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 2: Table 2

Table 2: Average Annual EPA Burden and Cost – NSPS for Stationary Combustion Turbines (40 CFR Part 60, Subpart KKKK)(Renewal)
					46.67	62.9	25.25
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 (F=Ex0.05)	(G) Clerical person-hours per year (G=Ex0.1)	(H) Cost, $ b
Report Review
1. Notification of construction/reconstruction c	1	1	1	47	47	2.35	4.7	$2,459.98
2. Notification of actual startup d	0.5	1	0.5	47	23.5	1.18	2.35	$1,229.99
3. Notification of performance test	2	1	2	199	398	19.9	39.8	$20,831.32
4. Notification of demonstration of CEMS e	2	1	2	15	30	1.5	3	$1,570.20
5. Initial notification of compliance	2	1	2	47	94	4.7	9.4	$4,919.96
6. Compliance report f	2	1	2	542	1084	54.2	108.4	$56,736.56
TOTAL ANNUAL BURDEN AND COST (rounded)g					1,930			$87,700
Assumptions:
a We have assumed that there is an average of 542 sources currently subject to the regulations and an additional 47 respondents per year will become subject. The ICR assumes the industry continues to grow at a constant rate after the rule has been fully implemented.
b This cost is based on the following hourly labor rates times a 1.6 benefits multiplication factor to account for government overhead expenses: $62.90 for Managerial, $46.67 for Technical, and $25.25 Clerical. These rates are from the Office of Personnel Management (OPM) “2014 General Schedule” which excludes locality rates of pay.
c We have assumed that each respondent will take one hour each to review the notification of construction/reconstruction report.
d We have assumed that it will take 0.5 hours for each respondent to review the actual startup report.
e We have assumed that of the 47 new respondents, only 15 of these respondents will review the notification of demonstration of CEMS report.
f We have assumed that it will take 2 hours once per year to review the compliance report.
g Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.