Burden Calculation Tables

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Overview

Industry Burden
Agency Burden

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Sheet 1: Industry Burden

Table 1: Annual Respondent Burden and Cost – NSPS for Petroleum Dry Cleaners (40 CFR Part 60, Subpart JJJ) (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 (AxB)	(D) Respondents per year a	(E) Technical person-hours per year (CxD)	(F) Management person-hours per year (Ex0.05)	(G) Clerical person-hours per year (Ex0.01)	(H) Cost, $ b		Respondant Rates (Source: United States Department of Labor, Bureau of Labor Statistics, June 2017, “Table 2. Civilian Workers, by occupational and industry group.”)
1. Applications	N/A									Labor Type	Total Compensation ($/hr)	Loaded Rate (Rate + 110%rate)
2. Survey and Studies	N/A									Mgmt.	$71.12	$149.35
3. Reporting Requirements										Tech.	$53.80	$112.98
A. Familiarization with regulatory requirements	See 4E									Cler.	$26.10	$54.81
B. Required activities
Initial performance test c, d	61	1	61	20	1,220	61	122	$153,632.89
Repeat of performance test c, d, e	61	1	61	4	244	12.2	24.4	$30,726.58
C. Create information	See 3B
D. Gather existing information	See 3B
E. Write report
Notification of construction/ modification c, f	2	1	2	20	40	2	4	$5,037.14
Notification of actual startup c, f	2	1	2	20	40	2	4	$5,037.14
Notification of initial performance test c , f	2	1	2	20	40	2	4	$5,037.14
Report of performance test	See 3B
Subtotal for Reporting Requirements					1,822			$199,471
4. Recordkeeping requirements
A. Familiarization with regulatory requirements	See 3A
B. Plan activities	See 4C
C. Implement activities	See 3B
D. Develop record system	N/A
E. Time to enter information
Record of all information required by the standard g	1	1.2	1.2	20	24	1.2	2.4	$3,022.29		Hours per Response
F. Time for audits	N/A									1,850	# hours
Subtotal for Recordkeeping Requirements					28			$3,022		84	# responses
TOTAL LABOR BURDEN AND COSTS (rounded) h					1,850			$202,000		22	hr/resp
TOTAL CAPITAL and O&M COST (rounded) h								$0
GRAND TOTAL (rounded) h								$202,000
Assumptions:
a We have assumed that there are approximately 1,120 existing sources that are currently subject to the rule with an estimated 20 new additional sources per year over the next three years. The rule stipulates that only new sources with one-time-only requirements are subject to this subpart. We therefore, concluded that the number of respondents for this renewal ICR is 20 sources per year.
b This ICR uses the following labor rates: $149.35 per hour for Executive, Administrative, and Managerial labor; $112.98 per hour for Technical labor, and $54.81 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% to account for the benefit packages available to those employed by private industry.
c This is a one-time only activity for recording the initial performance test.
d We have assumed that it will take 61 hours for each respondent to complete the required activity.
e We have assumed that 20 percent of respondents will have to repeat initial performance tests due to failure.
f We have assumed that it will take 2 hours for respondents to write report.
g We have assumed that it will take each respondent one hour to enter all required information, including any instances of startup, shutdown, and malfunction.
h Totals have been rounded to 3 significant values. Figures may not add exactly due to rounding.

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Sheet 2: Agency Burden

Table 2: Average Annual EPA Burden and Cost - NSPS for Petroleum Dry Cleaners (40 CFR Part 60, Subpart JJJ) (Renewal)
					$48.08	$64.80	$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 (AxB)	(D) Plants per year a	(E) Technical person-hours per year (CxD)	(F) Management person-hours per year (Ex0.05)	(G) Clerical person-hours per year (Ex0.1)	(H) Cost, $ b		Agency Rates Source: Office of Personnel Management (OPM), 2017 General Schedule
1. Initial performance test c	16	1	16	20	320	16	32	$17,254.91			Hourly Mean Wage	With Fringe & Overhead
2 Repeat performance test c, d	16	1	16	4	64	3.2	6.4	$3,450.98		(GS- 12, step 1) - Tech.	30.05	$48.08
3. Report review										(GS- 13, step 5) - Mgmt.	40.5	$64.80
Notification of construction/reconstruction c	2	1	2	20	40	2	4	$2,156.86		(GS-6, step 3) - Cler.	16.26	$26.02
Notification of actual startup c	1	1	1	20	20	1	2	$1,078.43
Initial performance test c, e	7.5	1	7.5	20	150	7.5	15	$8,088.24
Repeat performance test c, f	7.5	1	7.5	4	30	1.5	3	$1,617.65
TOTAL (rounded) g					718			$33,600
Assumptions:
a We have assumed that there are approximately 1,120 existing sources that are currently subject to the rule with an estimated 20 new additional sources per year over the next three years. The rule stipulates that only new sources with one-time-only requirements are subject to this subpart. We therefore concluded that the number of respondents for this renewal ICR is 20 sources per year.
b This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: Managerial rate of $64.80 (GS-13, Step 5, $40.50 + 60%), Technical rate of $48.08 (GS-12, Step 1, $30.05 + 60%), and Clerical rate of $26.02 (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 This is a one-time only activity.
d We have assumed that 20 percent of respondents will have to repeat performance test
e We have assumed that EPA will take 7.5 hours to review the initial performance test report.
f We have assumed that EPA will have to review the repeat performance test report for 20 percent of respondents who submit an initial performance test report.
g Totals have been rounded to 3 significant values. Figures may not add exactly due to rounding.