Calculation Tables for ICR 1052.11

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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 Fossil Fuel Fired Steam Generating Units (40 CFR Part 60, SubpartD) (Renewal)
					103.97	129.93	51.79
Burden Item	(A) Person hours per occurrence	(B) Number 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) Cost, ($) b
1. Applications	N/A
2. Survey and Studies	N/A
3. Reporting Requirements
A. Familiarization with Regulatory Requirements c	1	1	1	660	660	33	66	$76,326.03
B. Required activities
Initial performance test d	N/A
C. Create information d	N/A
D. Gather Existing Information	See 3E
E. Write report
Notification of construction/reconstruction d	N/A
Notification of anticipated/actual startup d	N/A
Notify of emission test d	N/A
Report of initial emission test d	N/A
Excess emissions report e	1	2	2	660	1,320	66	132	$152,652.06
Subtotal Reporting Requirements					2,277			$228,978
4. Recordkeeping Requirements
A. Familiarization with Regulatory Requirements c	See 3A
B. Plan activities	See 4C
C. Implement activities	See 3B
D. Develop record system	N/A
E. Time to check computer system and calibrate continuous monitors f	0.25	365	91.25	660	60,225	3,011.25	6,022.5	$6,964,750.24
F. Time to Train Personnel	N/A
G. Time For Audits	N/A
Subtotal Recordkeeping Requirements					69,259			$6,964,750
TOTAL LABOR BURDEN AND COST(rounded) g					71,500			$7,190,000
Capital and O&M COST								$9,900,000
Grand Total								$17,100,000
										54
Assumptions:										hr/response
a We have assumed that the average number of respondents that will be subject to the rule will be 660. There will be no additional new sources that will become subject to the rule over the three-year period of this ICR.
b This ICR uses the following labor rates: Managerial $129.93 ($61.87+ 110%); Technical $103.97 ($49.51 + 110%); and Clerical $51.79 ($24.66 + 110%). 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. This ICR assumes that Managerial hours are 5% of Technical hours, and Clerical hours are 10% of Technical hours.
c We assume that all respondents will have to familiarize with regulatory requirements and it will take 1 hour per respondent to familiarize with regulatory requirements.
d There have been no new subpart D units since 1986, and new units are not expected over the three-year period of this ICR; therefore, this burden item is not applicable.
e We assume that each source will submit a semiannual report due to excess emission and monitoring systems performance over the three-year period.
f We assume that respondents conduct this activity on a daily basis, and that plant operations occur 365 days per year.
g 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 Fossil Fuel Fired Steam Generating Units (40 CFR Part 60, Subpart D) (Renewal)
					46.67	62.9	25.25
Burden Item	(A) EPA Hours per Occurrence	(B) Number of occurrences per plant per year	(C) EPA Person hour per year (C=AxB)	(D) Plants per year a	(E) Technical hours per year (E=CxD)	(F) Management hours per year (F=Ex0.05)	(G) Clerical hours per year (G=Ex0.10)	(H) Cost, ($) b
Report Review
Notification of construction	N/A
Notification of anticipated startup	N/A
Notification of actual startup	N/A
Notification of Initial Test
Sulfur dioxide c	N/A
Particulate matter c	N/A
Nitrogen oxides c	N/A
Review Initial Test Results
Sulfur dioxide c	N/A
Particulate matter c	N/A
Nitrogen oxides c	N/A
Review Notification of CMS Demonstration
Sulfur dioxide c	N/A
Particulate matter c	N/A
Nitrogen oxides c	N/A
Review CMS Performance Demonstration
Sulfur dioxide c	N/A
Particulate matter c	N/A
Nitrogen oxides	N/A
Review excess emission reports d	1	2	2	460	920	46	92	$48,152.80
Review sulfur dioxide compliance reports d, e
Coal-Fired units	2	2	4	133	532	26.6	53.2	$27,844.88
Oil-Fired units	2	2	4	67	268	13.4	26.8	$14,027.12
Travel expenses	N/A
TOTAL ANNUAL BURDEN AND COST (rounded) f					1,980			$90,000
Assumptions:
a We have assumed that the average number of respondents that will be subject to the rule will be 660. There will be no additional new sources that will become subject to the rule over the three-year period of this ICR.
b This ICR uses the following labor rates: Managerial $62.90 (GS-13, Step 5, $39.31 + 60%); Technical $46.67 (GS-12, Step 1, $29.17 + 60%); and Clerical $25.25 (GS-6, Step 3, $15.78 + 60%). These rates are from the Office of Personnel Management (OPM), 2014 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. This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours.
c There have been no new subpart D units since 1986, and new units are not expected over the three-year period of this ICR; therefore, this burden item is not applicable.
d We assume that approximately 70 percent of the sources monitor via CEM and that approximately 30 percent use fuel sampling and analysis.
e Units using fuel sampling and analysis submit sulfur dioxide compliance reports instead of excess emission reports, which are based on CEM data. The figures used in this category are based on research performed during regulation revision.
f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding