Burden Calculation Tables

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Overview

Table 1a
Table 1b
Table 1c-Affect Sector Summary
Table 2
Responses

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Sheet 1: Table 1a

Table 1a: Annual Respondent Burden and Cost for Private Facilities– NESHAP for Engine Test Cells/Stands (40 CFR Part 63, Subpart PPPPP) (Renewal)
					112.98	149.35	54.81
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 yeara	(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 yearb
1. Applications	N/A
2. Surveys and studies	N/A
3. Reporting requirements
A. Familiarization with regulatory requirements a	4	1	4	16	64	3.2	6.4	$8,059.42
B. Notificationsc
Initial notifications	2	0.3	0.6	1	0.6	0.03	0.06	$75.56
Notification of construction/reconstruction	2	0.3	0.6	1	0.6	0.03	0.06	$75.56
Notification of actual startup	2	0.3	0.6	1	0.6	0.03	0.06	$75.56
C. Create information	See 3B
D. Gather existing information	See 3E
E. Write report
Start-up Shutdown and Malfunction Pland	20	0.3	6	1	6	0	1	$755.57
Compliance status reporte	4	2	8	16	128	6	13	$16,118.85
Performance evaluation report	16	0.3	4.8	1	4.8	0.2	0.5	$604.46
Subtotal for Reporting Requirements						235		$25,765
4. Recordkeeping requirements
A. Initial performance evaluationf	330	0.3	99	1	99	5.0	9.9	$12,466.92
B. Monitoring demonstrationg	148	0.3	44.4	1	44.4	2.2	4.4	$5,591.23
C. Repeat performance evaluationh	330	1	330	0	0	0	0	$0
D. Maintain records of CEMS performancei	1.5	52	78	16	1248	62.4	124.8	$157,158.77		Note: Number of occurrences updated to 52 weeks (footnote says weekly basis.)
Subtotal for Recordkeeping Requirement						1,600		$175,217
TOTAL LABOR BURDEN AND COST (rounded)j						1,840		$201,000
Total CAPITAL and O&M COST (rounded)j								$5,300
GRAND TOTAL (rounded)j								$206,000
Assumptions:
a We have assumed that the average number of private sources subject to the rule will be 15, and that one new facility will become subject to the rule over the three-year period of this ICR. This ICR assumes that all sources will incur a burden to re-familiarize themselves with the regulatory requirements each year.
b This ICR uses the following labor rates: $149.35 per hour for Managerial labor; $112.98 per hour for Technical labor, and $54.31 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2017, 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 there will be one new or reconstructed source over the next three years.
d We have assumed that the one new source will use controls to comply with the standard and therefore the one-time SSM plan requirement will occur during this ICR period. We have assumed that this one new source will not develop a site-specific monitoring and inspection plan for catalytic oxidizer controls.
e Compliance status reports are required semiannually. We have assumed that deviations get reported as part of the semiannual compliance status report. We have assumed that all of the sources that had an SSM of a control device was consistent with the SSM plan and therefore no separate SSM report burden is estimated.
f The technical persons-hours per occurrence were taken from the ESD manual Table 4 “Burden of Performance Tests and Continuous Monitoring System (CMS) Demonstrations” (Volume X, Section 2.2).
g Since there is only one new respondent, we have assumed that it will not have to repeat the performance evaluations due to failure.
h We have assumed that owners and operators will maintain monitoring records on a weekly basis.
i We assume all of the recordkeeping and reporting burden from the rule at federal facilities will be conducted by federal employees.
j Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 2: Table 1b

Table 1b: Annual Respondent Burden and Cost for Federal Facilities – NESHAP for Engine Test Cells/Stands (40 CFR Part 63, Subpart PPPPP) (Renewal)
					48.08	64.8	26.02
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 yeara	(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 yearb
1. Applications	N/A
2. Surveys and studies	N/A
3. Reporting requirements
A. Familiarization with regulatory requirementsc	4	1	4	3	12	0.6	1.2	$647.06
B. Notificationsc
Initial notifications	2	1	2	0	0	0	0	$0
Notification of construction/reconstruction	2	1	2	0	0	0	0	$0
Notification of actual startup	2	1	2	0	0	0	0	$0
C. Create information	See 3B
D. Gather existing information	See 3E
E. Write report
Start-up Shutdown and Malfunction Planc	20	0.3	6	0	0	0	0	$0
Compliance status reportd	4	2	8	3	24	1.2	2.4	$1,294.13
Performance evaluation reporte	16	1	16	0	0	0	0	$0
Subtotal for Reporting Requirements						41		$1,941
4. Recordkeeping requirements
A. Initial performance evaluationf, g	330	1	330	0	0	0	0	$0
B. Monitoring demonstrationf, g	148	1	148	0	0	0	0	$0
C. Repeat performance evaluationf, g, h	330	1	330	0	0	0	0	$0
D. Maintain records of CEMS performancei	1.5	52	78	3	234	11.7	23.4	$12,617.75
Subtotal for Recordkeeping Requirementsk						269		$12,618
TOTAL LABOR BURDEN AND COST (rounded)k						310		$14,600			2,150
Total CAPITAL and O&M COST (rounded)k								$900
GRAND TOTAL (rounded)k								$15,500			$215,600
Assumptions:
a We have assumed that the average number of existing Federal sources subject to the rule will be 3, and that no new Federal facilities will become subject to the rule over the three-year period of this ICR. This ICR assumes that all sources will incur a burden to re-familiarize themselves with the regulatory requirements each year.
b This cost is based on the following hourly labor rates, increased by 60% to account for the benefit packages available to government employees: $64.80 for Managerial (GS-13, Step 5, $40.50+60%), $48.08 for Technical (GS-12, Step 1, $30.05 + 60%) and $26.02 Clerical (GS-6, Step 3, $16.26 + 60%). These rates are from the Office of Personnel Management (OPM) “2017 General Schedule” which excludes locality rates of pay.
c We have assumed that there will be no new or reconstructed Federal sources over the next three years.
d Compliance status reports are required semiannually. We have assumed that deviations get reported as part of the semiannual compliance status report. We have assumed that all of the sources that had an SSM of a control device was consistent with the SSM plan and therefore no separate SSM report burden is estimated.
e We have assumed that no Federal respondents need to conduct the initial performance evaluation, since there are no new or reconstructed Federal sources over the next three years.
f We have assumed that no Federal respondents need to keep records for initial performance evaluation related activities, since there are no new or reconstructed Federal sources over the next three years.
g The technical persons-hours per occurrence were taken from the ESD manual Table 4 “Burden of Performance Tests and Continuous Monitoring System (CMS) Demonstrations” (Volume X, Section 2.2).
h Since there are no new respondents, it is assumed no respondents will have to repeat the performance evaluations due to failure.
i We have assumed that owners and operators will maintain monitoring records on a weekly basis.
j We assume all of the recordkeeping and reporting burden from the rule at federal facilities will be conducted by federal employees.
k Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: Table 1c-Affect Sector Summary

Table 1c: Annual Respondent Burden and Cost Breakdown by Affected Sector– NESHAP for Engine Test Cells/Stands (40 CFR Part 63, Subpart PPPPP) (Renewal)
Affected Sector	Number of Response	Labor Hours			Labor Cost	Capital and O&M Cost
		Reporting	Recordkeeping	Total
Private	34	235	1,600	1,840	$201,000	$5,300
Public (Federal)	6	41	269	310	$14,600	$900
Total	40	276	1,869	2,150	$216,000	$6,200
Total hours per response	54

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Sheet 4: Table 2

Table 2: Average Annual EPA Burden and Cost - NESHAP for Engine Test Cells/Stands (40 CFR Part 63, Subpart PPPPP) (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 yeara	(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
1. Attend CEMS performance evaluation	32	0.3	9.6	1	9.6	0.48	0.96	$517.65
2. Repeat performance evaluation
a.       Retesting preparation	12	1	12	0	0	0	0	$0
b.       Attend retesting	32	1	32	0	0	0	0	$0
3. Deviation – enforcement activitiesc	16	1	16	4	64	3.2	6.4	$3,451.01
4. Reporting requirements
a.       Review waiversd	2	2	4	0	0	0	0	$0
b.        Review reports
Review initial notifications	2	0.3	0.6	1	0.6	0.03	0.06	$32
Compliance status reporte	2	2	4	19	76	3.8	7.6	$4,098.07
Performance evaluation report	2	0.3	0.6	1	0.6	0.0	0.06	$32.35
Subtotals Labor Burden and cost					150.8	7.54	15.08	$8,131.44
TOTAL ANNUAL BURDEN AND COST (rounded)f					173			$8,130
Assumptions:
a We have assumed that the average number of existing sources subject to the rule will be 18, and that one new facility will become subject to the rule over the three-year period of this ICR. That facility is not assumed to require repeat performance evaluation testing.
b This cost is based on the following hourly labor rates, increased by 60% to account for the benefit packages available to government employees: $64.80 for Managerial (GS-13, Step 5, $40.50+60%), $48.08 for Technical (GS-12, Step 1, $30.05 + 60%) and $26.02 Clerical (GS-6, Step 3, $16.26 + 60%). These rates are from the Office of Personnel Management (OPM) “2017 General Schedule” which excludes locality rates of pay.
c We have assumed that 20 percent of all respondents will be out of compliance.
d We have assumed that none of the respondents are submitting waivers for recordkeeping and reporting requirements.
e Compliance status reports review is required semiannually. We assumed that deviations get reported as part of the semiannual compliance status report.
f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 5: Responses

Total Annual Responses
(A)	(B)	(C)	(D)	(E)
			Number of Existing Respondents That Keep Records But Do Not Submit Reports	Total Annual Responses
Information Collection Activity	Number of Respondents	Number of Responses		E=(BxC)+D
Compliance status report	19	2	0	38
Initial notifications	1	0.3	0	0.3
Notification of construction/reconstruction	1	0.3	0	0.3
Notification of actual startup	1	0.3	0	0.3
Start-up Shutdown and Malfunction Plan	1	0.3	0	0.3
Performance evaluation report	1	0.3	0	0.3
			Total	40