Burden calculations

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Overview

Industry
Agency
Respondents
Capital-Startup and O&M

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Sheet 1: Industry

Burden Item	A	B	C	D	E	F	G	H
	Technical person-hours per occurrence	No. of occurrences per respondent per year	Technical person-hours per respondent per year (AxB)	Respondents per year a	Technical hours per year (CxD)	Management hours per year (Ex0.05)	Clerical hours per year (Ex0.10)	Total cost per year b		Respondant Rates (Source: http://www.bls.gov/news.release/ecec.t02.htm)
1. Applications	N/A									Labor Type	Total Compensation ($/hr)	Loaded Rate (Rate + 110%rate)
2. Survey and Studies	N/A									Mgmt.	$65.92	$138.43
3. Reporting Requirements										Tech.	$50.69	$106.45
A. Familiarize with regulation requirements d,h	40	1	40	4	160	8	16	$18,983.66		Cler.	$25.13	$52.77
B. Required activities
1) Initial stack test and report c	40	1	40	1	40	2	4	$4,745.92
2) Annual stack test and test report e, h	40	0.33	13.2	4	52.8	2.64	5.28	$6,265
3) Operator training and qualification
a) Establish and teach operator qualification course c, d	64	1	64	1	64	3.2	6.4	$7,593.47
b) Obtain operator qualification c, d	72	1	72	1	72	3.6	7.2	$8,542.65
c) Annual refresher course	12	1	12	1	12	0.6	1.2	$1,423.77
d) Initial review of site-specific information	See 3A
e) Annual review of site-specific information e	8	1	8	4	32	1.6	3.2	$3,796.73
4) Establish operating parameters (maximum and minimum) c	40	1	40	1	40	2	4	$4,745.92
5) Continuous parameter monitoring (including CEMS)	11	1	11	4	44	2.2	4.4	$5,220.51
C. Create Information	See 3B
D. Gather Existing Information	See 3E
E. Write report
1) Notification of construction (includes siting analysis) c	160	1	160	1	160	8	16	$18,983.66
2) Notification of start-up (includes monitoring plan)	40	1	40	1	40	2	4	$4,745.92
3) Notification of initial performance test c	2	1	2	1	2	0.1	0.2	$237.30
4) Notification of initial CMS Demonstration b	2	1	2	1	2	0.1	0.2	$237.30
5) Initial Compliance Report	40	1	40	1	40	2	4	$4,745.92
6) Annual Compliance Report	40	1	40	4	160	8	16	$18,984
7) Status report for operators that are off-site for more than 2 weeks f	8	1	8	1	8	0.4	0.8	$949.18
8) Corrective action summary for operators that are off-site for more than 2 weeks f	8	2	16	1	16	0.8	1.6	$1,898.37
9) Semiannual Deviation Report g	24	2	48	0.4	19.2	0.96	1.92	$2,278.04
Subtotal for Reporting Requirements					1109			$114,377
4. Recordkeeping Requirements
A. Familiarize with regulation requirements	See 3A
B. Plan activities	N/A
C. Implement activities:	N/A
D. Develop record system	N/A
E. Record Information
1) Records of operating parameters	2	52	104	0	0	0	0	$0
2) Records of exceedances of the operating parameters	2	1	2	0.4	0.8	0.04	0.08	$94.92
3) Records of stack tests	2	1	2	4	8	0.4	0.8	$949.18
4) Records of siting analysis	2	1	2	1	2	0.1	0.2	$237.30
5) Records of persons who have reviewed operating procedures	2	1	2	4	8	0.4	0.8	$949.18
6) Records of persons who have completed operator training	2	1	2	4	8	0.4	0.8	$949.18
7) Records of persons who meet operator qualification criteria	2	1	2	4	8	0.4	0.8	$949.18
8) Records of monitoring device calibration	2	1	2	4	8	0.4	0.8	$949.18
9) Records of site-specific documentation	24	1	24	4	96	4.8	9.6	$11,390.20
F. Time to train personnel	See 3B
G. Time for audits	N/A
Subtotal for Recordkeeping Requirements					160			$16,468
TOTAL ANNUAL BURDEN AND COST (Rounded)i					1270			$131,000
Capital and O&M Costs (see Section 6(b)(iii))								$694,000
TOTAL (Rounded)i					1270			$825,000
						99	hr/response
Assumptions:
a. Assumed that there are 4 existing facilities on average with 6 units. Burden estimates based on a "per respondent" basis, not a "per unit" basis. Assumed that there will be a total of 2 new sources and 1 modified source over the next three-year period, averaging to 1 new respondent per year. Estimate based on EPA's 2016 SSI Inventory.
b. This ICR uses the following labor rates: $138.43 per hour for Executive, Administrative, and Managerial labor; $106.45 per hour for Technical labor, and $52.77 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2016, “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. One-time only costs
d. Costs incurred by a facility regardless of the number of affected units at the plant.
e. Annual Costs. Annual costs are not incurred until the second year of operation.
f. Assumed that 10 percent of the facilities (conservatively rounded to one) would not have a qualified operator available for more than two weeks at least once a year. Assume that this would require only two corrective action summaries.
g. Assumed that 10 percent of the facilities would have an exceedance during the year.
h. Facilities may test every three years if certain requirements are met, thus annual testing is divided by three to give a per year cost. It is assumed most facilities would meet the requirements.
i. Totals are rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 2: Agency

Burden Item	A	B	C	D	E	F	G	H		EPA Source: http://www.opm.gov/oca/11tables/html/gs_h.asp
	Technical person-hours per occurrence	No. of occurrences per respondent per year	Technical person-hours per respondent per year (AxB)	Respondents per year a	Technical hours per year (CxD)	Management hours per year (Ex0.05)	Clerical hours per year (Ex0.10)	Total cost per year b			Hourly Mean Wage	With Fringe & Overhead
1. Applications	N/A									(GS- 12, step 1) - Tech.	29.76	$47.62
2. Read and Understand Rule Requirements	40	1	40	4	160	8	16	$8,544.00		(GS- 13, step 5) - Mgmt.	40.1	$64.16
3. Required Activities										(GS-6, step 3) - Cler.	16.1	$25.76
A. Observe stack tests c	48	1	48	1	48	2.4	4.8	$2,563.20
B. Excess emissions - Enforcement activities	24	1	24	1	24	1.2	2.4	$1,281.60
C. Create Information	N/A
D. Gather Information	N/A
E. Report Reviews
1. Review initial notifications d	40	2	80	1	80	4	8	$4,272
2. Review initial compliance report	40	1	40	1	40	2	4	$2,136
3. Review annual compliance report	8	1	8	4	32	1.6	3.2	$1,709
4. Review semi-annual excess emission and parameter exceedance report	16	2	32	0.4	12.8	0.64	1.28	$683.52
5. Review status reports and corrective action summary for operators off-site	4	1	4	1	4	0.2	0.4	$213.60
F. Prepare annual summary report e	4	1	4	4	16	0.8	1.6	$854.40
TOTAL ANNUAL COST (rounded) f					479			$22,300
Assumptions:
a. Assumed that there are 4 existing facilities on average with 6 units. Burden estimates based on a "per respondent" basis, not a "per unit" basis. Assumed that there will be a total of 2 new sources and 1 modified source over the next three-year period, averaging to 1 new respondent per year. Estimates based on EPA's 2016 SSI Inventory
b.This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: $64.16 Managerial rate (GS-13, Step 5, $40.10 x 1.6), $47.62 Technical rate (GS-12, Step 1, $29.76 x 1.6), and $25.76 Clerical rate (GS-6, Step 3, $16.10 x 1.6). These rates are from the Office of Personnel Management (OPM) “2016 General Schedule”, which excludes locality rates of pay.
c. Assumes EPA personnel attend 20 percent of the stack tests (conservatively rounded up to one plant). Assume all facilities meet reduced testing requirements.
d. Includes notification of construction and notification of start-up for new units.
e. Using four hours per state to write annual summary report.
f. Totals rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: Respondents

Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports				Total Annual Responses
Year	(A) Number of New Respondents1	(B) Number of Existing Respondents2	(C) Number of Existing Respondents that keep records but do not submit reports	(D) Number of Existing Respondents That Are Also New Respondents	(E) Number of Respondents (E=A+B+C-D)		(A) Information Collection Activity	(B) Average Number of Respondents	(C) Number of Responses	(D) Number of Existing Respondents That Keep Records But Do Not Submit Reports	(E) Total Annual Responses E=(BxC)+D
1	1	3	0	0	4		Notification of Construction	1	1	0	1
2	1	4	0	0	5		Notification of Start-up	1	1	0	1
3	1	5	0	0	6		Notification of Initial Performance Test	1	1	0	1
Average	1	4	0	0	5		Notification of Initial CMS Demonstration	1	1	0	1
1 Assumed that there will be 2 new sources and 1 modified source over the next three years, averaging to 1 new respondent per year.							Initial Compliance Report	1	1	0	1
2 Assumed there are 4 existing facilities with 6 units on average. Based on EPA's 2016 SSI Inventory.							Annual Compliance Report a	4	1	0	4
							Status report for operators that are off-site for more than 2 weeks b	1	1	0	1
							Corrective action summary for operators that are off-site for more than 2 weeks b	1	2	0	2
							Semiannual Deviation Report	0.4	2	0	0.8
										Total	13
							a Facilities may test every three years if certain requirements are met, and it is assumed most facilities would meet the requirements. However, annual compliance reports must be submitted regardless of whether a performance test is conducted during the reporting period.
							b Assumed that 10 percent of the facilities (conservatively rounded to one) would not have a qualified operator available for more than two weeks at least once a year. Assumed this would require only two corrective action summaries.

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Sheet 4: Capital-Startup and O&M

(A)	(B)	(C)	(D)	(E)	(F)	(G)
Item	Capital/Startup Cost for One Respondent	Number of New Respondentsa	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)
CPMSb	$226,946	1	$226,946	$81,160	4	$324,640
Stack testing c	$61,350	1	$61,350	$61,350	1.32	$80,982
Filing cabinetd	$100	1	$100				total
Total			$288,000			$406,000	$694,000
a. Assumed that there are 4 existing facilities on average with 6 units. Burden estimates based on a "per respondent" basis, not a "per unit" basis. Assumed that there will be a total of 2 new sources and 1 modified source over the next three-year period, averaging to 1 new respondent per year. Estimates based on EPA's 2016 SSI Inventory
b. Based on estimated monitoring costs provided in regulatory support documentation.
c. Total estimated cost for initial stack test, including Method 5 (PM), Method 9 (opacity), Method 10 (CO), Method 26 (HCl), Method 29 (metals), Method 23 (CDD/CDF), Method 7E (NOx), and Method 6C (SO2). Facilities may test every three years if certain requirements are met, and it is assumed most facilities would meet the requirements.
d. Assumed $100 for purchase of filing cabinet to house copy of rule, records, and report copies.