Burden Tables

---

Overview

VVV RTR Cost Basis
# Respondents
# Responses
Respondent Burden
Agency Burden
Capital & O&M

---

Sheet 1: VVV RTR Cost Basis

2 existing Group 1 facilities and 11 existing Group 2 facilities will have burden associated with familiarizing themselves with the revised rule.

Each of these facilities is currently in compliance with the rule requirements, therefore, there are no Capital & O&M costs associated with the rule amendments.

---

Sheet 2: # Respondents

Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
	(A)	(B)	(C)	(D)	(E)
Year	Number of New Respondents1	Number of Existing Respondents	Number of Existing Respondents that keep records but do not submit reports	Number of Existing Respondents That Are Also New Respondents	Number of Respondents
					(E=A+B+C-D)
1	0	0	0	0	0
2	0	0	0	0	0
3	0	0	0	0	0
Average	0	0	0	0	0
1 New respondents include 13 existing sources subject to the rule.

---

Sheet 3: # Responses

Total Annual Responses
(A) Information Collection Activity	(B) 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
Initial notification	0	1	0	0
Notification of compliance status	0	1	0	0
Request for extension of compliance	0	1	0	0
Notification of special compliance requirements	0	1	0	0
Notification of initial performance test	0	1	0	0
Additional notification requirements for sources with CMS	0	1	0	0
Notification of adjustments to time periods	0	1	0	0
Notification of changes to information provided	0	1	0	0
Initial performance test report	0	1	0	0
Inspection and monitoring plan	0	1	0	0
Annual report	0	1	0	0
Excess emissions report	0	1	0	0
			Total	0
CMS - Continuous Monitoring System			hrs/response:	0.00

---

Sheet 4: Respondent Burden

Table 1: Annual Respondent Burden and Cost – NESHAP for Publicly Owned Treatment Works (40 CFR Part 63, Subpart VVV) (2016 RTR)										Source Type	No.
										Existing	13	(13 existing sources)
				Labor Rates:	$108.61	$143.26	$52.88			New (other sectors)	0	(0 new sources)
Burden item	A	B	C	D	E	F	G	H
	Person-hours per occurrence	Annual occurrences per respondent	Person-hours per respondent per year (AxB)	Respondents per year a	Technical hours per year (CxD)	Management hours per year (Ex0.05)	Clerical hours per year (Ex0.10)	Annual cost ($) b		ERG Notes:
1. Applications	N/A
2. Surveys and studies	N/A
3. Reporting requirements
A. Familiarization with rule requirements c	0.5	1	1	13	7	0.3	0.7	788
B. Required activities
Initial notificiation	2	1	2	0	0	0	0	0
Notification of compliance status	2	1	2	0	0	0	0	0
C. Create information	See 3B
D. Gather existing information	See 3B
E. Write reports
Request for extension of compliance	2	1	2	0	0	0	0	0
Notification of special compliance requirements	2	1	2	0	0	0	0	0
Notification of initial performance test	N/A
Additional notification requirements for source with CMS	2	1	2	0	0	0	0	0
Notification of adjustments to time periods	2	1	2	0	0	0	0	0
Notification of changes to information provided	2	1	2	0	0	0	0	0
Initial performance test report	N/A
Inspection and monitoring plan	N/A
Annual report	1	2	2	0	0	0.0	0.0	0
Excess emissions report	2	1	2	0	0	0	0	0
Reporting Subtotal					7			788
4. Recordkeeping
A. Familiarization with rule requirements	See 3A
B. Plan activities	See 3E
C. Implement activities	See 3E
D. Develop record system	See 3E
E. Time to enter information
Records of annual inspections	2	1	2	0	0	0	0	0
Records of inspections, defects, and repair delays	2	1	2	0	0	0	0	0
F. Time to transmit or disclose information	N/A
G. Time to train personnel	N/A
H. Time for audits	N/A
Recordkeeping Subtotal					0			0
TOTAL ANNUAL BURDEN AND COST (ROUNDED) d					7			790
TOTAL ANNUAL CAPITAL AND O&M COST (SEE SECTION 6(b)(iii))								0
GRAND TOTAL (LABOR, CAPITAL, AND O&M) d								790
CMS - Continuous Monitoring System
N/A - Not Applicable
Assumptions:
a EPA estimates thirteen existing sources will now be subject to reporting requirements. We do not expect any new sources will become subject to the rule over the next three years.
b This ICR uses the following labor rates: $108.61 (technical), $143.26 (managerial), and $52.88 (clerical). 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.” They have been increased by 110 percent to account for the benefit packages available to those employed by private industry. http://www.bls.gov/news.release/ecec.t02.htm
c This burden represents the time existing respondents spend familiarizing themselves with the rule amendments.
d Totals have been rounded to three significant digits. Figures may not add exactly due to rounding.

---

Sheet 5: Agency Burden

Table 2: Average Annual EPA Burden and Cost – NESHAP for Publicly Owned Treatment Works (40 CFR Part 63, Subpart VVV) (2016 RTR)
				Labor Rates:	$47.62	$64.16	$25.76
Burden item	A	B	C	D	E	F	G	H
	EPA person-hours per occurrence	Annual occurrences per respondent	EPA person-hours per respondent per year (AxB)	Respondents per year a	Technical hours per year (CxD)	Management hours per year (Ex0.05)	Clerical hours per year (Ex0.10)	Annual cost ($) b
Initial performance test	N/A
Repeat initial performance test	N/A
Report review
Initial notification c	2	1	2	0	0	0	0	0
Notification of compliance status	2	1	2	0	0	0	0	0
Request for extension of compliance	0.5	1	1	0	0	0	0	0
Notification of special compliance requirements	2	1	2	0	0	0	0	0
Notification of initial performance test	2	1	2	0	0	0	0	0
Additional notification requirements for sources with CMS	2	1	2	0	0	0	0	0
Notification of adjustments to time periods	2	1	2	0	0	0	0	0
Notification of changes to information provided	2	1	2	0	0	0	0	0
Initial performance test report	N/A
Inspection and monitoring plan	N/A
Annual report	1	2	2	0	0	0.0	0.0	0.00
Excess emissions report	N/A
TOTAL ANNUAL BURDEN AND COST (ROUNDED) d					0			0
CMS - Continuous Monitoring System
N/A - Not Applicable
Assumptions:
a EPA estimates an average of thirteen existing sources will be subject to the standard. We do not expect any new sources will become subject to the rule over the next three years.
b This ICR uses the following labor rates: $47.60 (technical), $64.16 (managerial), and $25.76 (clerical). These rates are from the Office of Personnel Management (OPM), 2016 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.
c Existing sources have no notification and reporting activities.
d Totals have been rounded to three significant digits. Figures may not add exactly due to rounding.

---

Sheet 6: Capital & O&M

No Capital/Startup or O&M costs for this ICR.