Burden Calculations Tables

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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 Sulfuric Acid Plants (40 CFR Part 60, Subpart H) (Renewal)
					108.28	144.03	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 = A x B)	(D) Respondents per yeara	(E) Technical person- hours per year (E = C x D)	(F) Management person hours per year (E x 0.05)	(G) Clerical person hours per year (E x 0.1)	(H) Total Cost Per yearb
1. Applications	N/A
2. Survey and Studies	N/A
3. Reporting requirements
A. Familiarization with rule requirementsc	1	1	1	53	53	2.65	5.3	$6,403.22
B. Required activities
Initial performance testsd	300	1	300	0	0	0	0	$0
Reference Method 9 teste	4	1	4	0	0	0	0	$0
Repeat of performance testsf	300	1	300	0	0	0	0	$0
C. Create information	See 3B
D. Gather existing information	See 3B
E. Write Report
Application of construction or modification	2	1	2	0	0	0	0	$0
Notification of actual startup	2	1	2	0	0	0	0	$0
Notification of physical or operational change	2	1	2	0	0	0	0	$0
Notification of demonstration of CMS	2	1	2	0	0	0	0	$0
Notification of initial performance test	2	1	2	0	0	0	0	$0
Semiannual report of excess emissionsg	40	2	80	53	4,240	212	424	$512,257.72
Subtotal for Reporting Requirements					4,937			$518,661
4. Recordkeeping requirements
A. Familiarization with rule requirements	See 3A
B. Plan activities	See 3A
C. Implement Activities	See 3A
D. Develop record system	N/A
E. Time to enter information
Records of operating parametersh	0.25	350	87.5	53	4637.5	231.88	463.75	$560,281.88
Record of conversion factors/calculationj,k	0.05	1,050	52.5	53	2782.5	139.13	278.25	$336,169.13
F. Time to train personnel	N/A
G. Time for audits	N/A
Subtotal for Recordkeeping Requirements					8,533			$896,451
TOTAL LABOR BURDEN AND COST (rounded)j					13,500			$1,420,000	$1,415,112
TOTAL CAPITAL AND O&M COST (rounded)j								$239,000
TOTAL LABOR BURDEN AND COST (rounded)j					13,500			$1,650,000
									127.358490566038
Assumptions:
a We have assumed that there are approximately 53 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three years.
b This ICR uses the following labor rates: $144.03 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 We have assumed that it will take one hour for each respondent to read instructions.
d We have assumed that it will take 300 hours for each respondent to complete an initial performance test.
e We have assumed that it will take four hours for each respondent to complete a reference Method 9 test.
f We have assumed that it will take 300 hours to repeat performance test due to failures.
g We have assumed that it will take 40 hours, twice a year, for each respondent to write an excess emission report.
h We have assumed that each respondent will enter information on records of operating parameters 350 times per year.
i We have assumed that records of conversion factors will be recorded three times daily, at 350 days per year, for a total of 3x350=1,050 times per year.
j 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 Sulfuric Acid Plants (40 CFR Part 60, Subpart H) (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 (Ex0.05)	Clerical person-hours per year (Ex0.1)	Cost, $ b
New facility
Initial performance test c	50	1	50	0	0	0	0	$0
Repeat performance test/observed d	24	1	24	0	0	0	0	$0
Review reports
Notification of construction	2	1	2	0	0	0	0	$0
Notification of actual startup	0.5	1	0.5	0	0	0	0	$0
Notification of initial test	0.5	1.2	0.6	0	0	0	0	$0
Review test results	8	1.2	9.6	0	0	0	0	$0
Notification of CMS demonstration	0.5	1	0.5	0	0	0	0	$0
Existing facility	0.5	1	0.5	0	0	0	0	$0
Excess emission reportse	4	2	8	53	424	21.2	42.4	$22,862.93
TOTAL ANNUAL BURDEN AND COST (rounded)f					488			$22,900
Assumptions:
a We have assumed that there are approximately 53 respondents, with no additional new or reconstructed sources becoming subject to the rule 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 We have assumed that it will take fifty hours for each respondent to perform the initial performance test.
d We have assumed that it will take twenty-four hours for each respondent to repeat the performance test due to failure.
e We have assumed that it will take four hours, twice per year, for each respondent to review the excess emission reports.
f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.