Burden Calculations Table

1051t14.xlsx

NSPS for Portland Cement Plants (40 CFR part 60, subpart F) (Renewal)

Burden Calculations Table

OMB: 2060-0025

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Overview

Table 1
Table 2
Capital and O&M


Sheet 1: Table 1

Table 1: Annual Respondent Burden and Cost – NSPS for Portland Cement Plants (40 CFR Part 60, Subpart F) (Renewal)















108.28 144.33 53.34



Burden item (A) (B) (C) (D) (E) (F) (G) (H)


Person hours per occurrence No. of occurrences per respondent per year Person hours per respondent per year
(C=AxB)
Respondent per year a Technical person- hours per year
(E=CxD)
Management person/ hours per year
(F=Ex0.05)
Clerical person hours per year
(G=Ex0.1)
Total Cost per year b


1. Applications N/A









2. Surveys and studies N/A









3. Reporting requirements










A. Familiarize with regulatory requirements c 1 1 1 95 95 4.75 9.5 $11,478.90


B. Required activities










Initial performance test d 36 1 36 2 72 3.6 7.2 $8,699.80


Repeat performance test e 36 1 36 1 36 1.8 3.6 $4,349.90


CEMS initial performance test f 8 1 8 2 16 0.8 1.6 $1,933.29


CEMS quarterly inspections g 2 4 8 2 16 0.8 1.6 $1,933.29


CEMS daily calibration drift tests h 0.3 330 99 2 198 9.9 19.8 $23,924.44


Daily monitoring (CEMS) i 0.5 330 165 2 330 16.5 33 $39,874.07


C. Create information See 3B









D. Gather existing information See 3E









E. Write report










Notification of construction/reconstruction 2 1 2 2 4 0.2 0.4 $483.32


Notification of actual startup 2 1 2 2 4 0.2 0.4 $483.32


Notification of physical or operational change 2 1 2 2 4 0.2 0.4 $483.32


Notification of demonstration of CEMS 2 1 2 2 4 0.2 0.4 $483.32


Notification of initial performance test j 2 1.5 3 2 6 0.3 0.6 $724.98


Report of performance test j 2 1.5 3 2 6 0.3 0.6 $724.98


Semiannual reports k 24 2 48 95 4,560 228 456 $550,987.08


Subtotal for Reporting Requirements



6,154 $646,564


4. Recordkeeping requirements










A. Familiarize with regulatory requirements See 3A









B. Plan activities See 3B









C. Implement activities See 3B









D. Develop record system N/A









E. Time to enter information










Daily production and kiln feed rates l 0.125 330 41.25 95 3,919 195.9375 391.875 $473,504.52


Data Collection m 0.1 330 33 95 3,135 156.75 313.5 $378,803.62


Records of startup, shutdown malfunction n 1.5 1 1.5 95 142.5 7.125 14.25 $17,218.35


F. Train personnel for CEMS maintenance o 16 2 32 2 64 3.2 6.4 $7,733.15


G. Audits 16 1 16 0 0 0 0 $0


Subtotal for Recordkeeping Requirements



8,349 $877,260
responses hr/response
TOTAL LABOR BURDEN AND COST (rounded) p



14,500 $1,520,000
204 71.078431372549
TOTAL CAPITAL AND O&M COST (rounded) p






$767,000


GRAND TOTAL (rounded) p






$2,290,000














Assumptions:










a We have assumed that the average number of respondents that will be subject to the rule will be 95 existing plants, operating 135 kilns. There will be no additional sources over the three-year period of this ICR. However, we assume that two existing plants will undergo modification or reconstruction which will require re-submittal or notifications and retesting.










b This ICR uses the following labor rates: $144.33 per hour for Executive, Administrative, and Managerial labor; $108.28 per hour for Technical labor, and $53.34 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 We have assumed that all new and existing respondents will take one hour to familiarize with the regulatory requirements each year.










d We have assumed that each respondent will take 36 hours to perform initial performance tests.










e We have assumed that one respondent will have to repeat initial performance tests..










f We have assumed that it will take each respondent eight hours to perform CEMS performance test.










g We have assumed that it will take each respondent 2 hours 4 times per year to perform CEMS inspections.










h We have assumed that it will take each respondent 0.3 hours 330 times per year to perform daily calibration drift tests.










i We have assumed that it will take each respondent 0.5 hours 330 times per year to perform daily CEMS monitoring.










j There will be a total of 3 performance tests per year (2 initial and 1 repeat) for two existing plants undergoing modification or reconstruction (3/2 = 1.5 tests/plant).










k We have assumed that it will take each respondent 24 hours two times per year to prepare semiannual reports.










l We have assumed that it will take each respondent 0.125 hours 330 times per year to enter daily production and kiln feed rates information.










m We have assumed that it will take each respondent 0.1 hours 330 times per year to enter data collection information.










n We have assumed that it will take each respondent 1.5 hours once per year to record SSM.










o We have assumed that it will take respondents 16 hours twice a year to train personnel on how to maintain the CEMS.










p Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.











Sheet 2: Table 2

Table 2: Average Annual EPA Burden and Cost – NSPS for Portland Cement Plants (40 CFR Part 60, Subpart F) (Renewal)












48.08 64.8 26.02
Activity (A) (B) (C) (D) (E) (F) (G) (H)
EPA person- hours per occurrence No. of occurrences per plant per year EPA person- hours per plant per year
(C=AxB)
Plants per year a Technical person- hours per year
(E=CxD)
Management person-hours per year
(F=Ex0.05)
Clerical person-hours per year
(G=Ex0.1)
Cost, $ b
Report review







Notification of construction/reconstruction c 2 1 2 2 4 0.2 0.4 $215.69
Notification of actual startup c, d 0.5 1 0.5 2 1 0.05 0.1 $53.92
Notification of physical and operational change c 2 1 2 2 4 0.2 0.4 $215.69
Notification of demonstration of CEMS 2 1 2 2 4 0.2 0.4 $215.69
Notification of initial performance test c, e 0.5 1.5 0.75 2 1.5 0.075 0.15 $80.88
Review test results c, f 8 1.5 12 2 24 1.2 2.4 $1,294.13
Review of semiannual reports g 4 2 8 95 760 38 76 $40,980.72
TOTAL LABOR BURDEN AND COST (rounded) h



918 $43,100









Assumptions:







a We have assumed that the average number of respondents that will be subject to the rule will be 95 existing plants, operating 135 kilns. There will be no additional sources over the three-year period of this ICR. However, we assume that two existing plants will undergo modification or reconstruction which will require re-submittal or notifications and retesting.







b This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: $64.80 Managerial rate (GS-13, Step 5, $40.50 x 1.6), $48.08 Technical rate (GS-12, Step 1, $30.05 x 1.6), and $26.02 Clerical rate (GS-6, Step 3, $16.26 x 1.6). These rates are from the Office of Personnel Management (OPM) “2017 General Schedule”, which excludes locality rates of pay.







c We have assumed that the number of existing plants that undergo construction or reconstruction will be two.







d We have assumed that it will take each 0.5 hours to review each notification of actual startup.







e We have assumed that it will take 0.5 hours to review each notification of performance test.







f We have assumed that it will take 8 hours to review each performance test report.







g We have assumed that it will take 4 hours two times per year to review semiannual reports.







h Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.








Sheet 3: Capital and O&M

Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A) (B) (C) (D) (E) (F) (G)
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)
CEMS $19,507 2 $39,014 $7,490 95 $711,550
Flow Meter $8,090 2 $16,180 $0 0 $0
Total

$55,200

$712,000
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