1789t10

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Overview

Industry
Agency

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Sheet 1: Industry

Table 1: Annual Respondent Burden and Cost – NESHAP for Natural Gas Transmission and Storage (40 CFR Part 63, Subpart HHH) (Renewal)
					108.28	144.33	53.34
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 (Ex0.05)	(G) Clerical person hours per year (Ex0.1)	(H) Total Cost per year b
1. Applications	N/A
2. Survey and Studies	N/A
3. Reporting requirements
A. Familiarize with regulatory requirementsc	2	1	2	55	110	5.5	11	$13,291.36
B. Required activities	N/A
C. Create information	N/A
D. Gather existing information	4	1	4	55	220	11	22	$26,582.71
E. Write Report										# of responses
i. Notification of construction/ reconstructiond	2	1	2	6	12	0.6	1.2	$1,449.97		6
ii. Notification of actual startupd	2	1	2	6	12	0.6	1.2	$1,449.97		6
iii. Notification of date of CMS performance evaluationd	2	1	2	6	12	0.6	1.2	$1,449.97		6
iv. Notification of planned date of performance testd	2	1	2	6	12	0.6	1.2	$1,449.97		6
v. Notification of compliance status reportd	4	1	4	6	24	1.2	2.4	$2,899.93		6
vi. Semiannual Periodic Report	4	2	8	55	440	22	44	$53,165.42		110
Subtotal for Reporting Requirements					968			$101,739.28		140	Total Response
4. Recordkeeping requirements										21	Hours/response
A. Familiarize with regulatory requirements	See 3A
B. Plan activitiesd	16	1	16	6	96	4.8	9.6	$11,599.73
C. Implement activities	N/A
D. Develop record system
i. Control equipmentd	4	1	4	6	24	1.2	2.4	$2,899.93
E. Time to enter information
i. Control device designd	4	1	4	6	24	1.2	2.4	$2,899.93
ii. Control equipment testingd	1	1	1	6	6	0.3	0.6	$724.98
iii. Control equipment inspection	8	2	16	55	880	44	88	$106,330.84
iv. Control equipment monitoring	1	2	2	55	110	5.5	11	$13,291.36
v. Control device CMS	1	6	6	55	330	16.5	33	$39,874.07
F. Time to train personnel	4	1	4	55	220	11	22	$26,582.71
G. Perform Audits	N/A
H. Retain records of actual throughput (facilities exempt under 63.1270(f)e	N/A
Subtotal for Recordkeeping Requirements					1,944			$204,203.55
TOTAL LABOR BURDEN AND COST (rounded)f					2,910			$306,000
TOTAL CAPITAL AND O&M COST (rounded)f								$0
GRAND TOTAL (rounded)f								$306,000
Assumptions:
a We have assumed that there are approximately 55 respondents subject to the rule, on average over the three year period. It is estimated that 6 additional new or reconstructed sources becoming subject to the rule annually over the next three years.
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 groups. 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 It is estimated that each source will familiarize themselves with the rule requireements each year.
d One-time requirement for the 6 new or reconstructed sources.
e Respondents are expected to maintain records of actual annual throughput as a standard business practice; therefore, there is no additional burden associated with these records under this rule.
f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 2: Agency

Table 2: Average Annual EPA Burden and Cost – NESHAP for Natural Gas Transmission and Storage (40 CFR Part 63, Subpart HHH) (Renewal)
					48.08	64.8	26.02
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 (Ex0.05)	(G) Clerical person-hours per year (Ex0.1)	(H) Cost, $ b
Review reports
a. Initial notification	2	1	2	6	12	0.6	1.2	$647.06
b. Preconstruction review application	4	1	4	6	24	1.2	2.4	$1,294.13
c. Performance test notification	2	1	2	6	12	0.6	1.2	$647.06
d. Compliance status notification	4	1	4	6	24	1.2	2.4	$1,294.13
e. Semiannual periodic reports	2	2	4	55	220	11	22	$11,862.84
TOTAL ANNUAL BURDEN AND COSTc					336			$15,700
Assumptions:
a We have assumed that there are approximately 55 respondents, on average. It is estimated that 6 additional new or reconstructed sources becoming subject to the rule annually over the next three years.
b This cost is based on the following hourly labor rates times a 1.6 benefits multiplication factor to account for government overhead expenses: $64.80 for Managerial, $48.08 for Technical, and $26.02 Clerical. These rates are from the Office of Personnel Management (OPM) “2017 General Schedule” which excludes locality rates of pay.
c Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.