Burden Calculation Table

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Overview

Respondent Burden
Agency Burden

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Sheet 1: Respondent Burden

Table 1: Annual Respondent Burden and Cost – NESHAP for Mercury (40 CFR Part 61, Subpart E) (Renewal)
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 hr/yr (E=CxD)	(F) Management person hr/yr (Ex0.05)	(G) Clerical person hr/yr (Ex0.1)	(H) Total Cost Per year b
1. Applications	N/A									Tech	$112.98
2. Survey and Studies	N/A									Mgmt	$149.35
3. Reporting requirements										Cler	$54.81
A. Familiarization with regulatory requirements c	1	1	1	107	107	5.35	10.7	$13,474.36		Respondant Rates (Source: United States Department of Labor, Bureau of Labor Statistics, June 2017, “Table 2. Civilian Workers, by occupational and industry group.”)
B. Required activities for New Sources										Labor Type	Total Compensation ($/hr)	Loaded Rate (Rate + 110%rate)
Initial performance test d	24	1	24	0	0	0	0	$0		Mgmt.	$71.12	$149.35
Repeat performance test e	24	0.2	4.8	0	0	0	0	$0		Tech.	$53.80	$112.98
C. Create information	See 3B									Cler.	$26.10	$54.81
D. Gather existing information	See 3B
E. Write reports
New Sources										Hours per Response
Notification of construction/reconstruction f	2	1	2	0	0	0	0	$0		20600	# hours
Notification of initial startup g	2	1	2	0	0	0	0	$0		128	# responses
Notification of actual startup g	2	1	2	0	0	0	0	$0		161	hr/resp
Report of initial performance test
Notification of initial performance test	2	1	2	0	0	0	0	$0
Existing Sources
Report of annual emission test h	12	1	12	100	1,200	60	120	$151,114.32
Submit semiannual report i	8	2	16	7	112	5.6	11.2	$14,104.00
Notification of parameter excursions j	4	2	8	7	56	2.8	5.6	$7,052.00
Subtotal for Reporting Requirements					1,696			$185,745
4. Recordkeeping requirements
A. Familiarization with regulatory requirements	See 3A
B. Plan activities	See 3B
C. Implement activities	See 3B
D. Develop record system
Record operating parameters k	0.25	365	91.25	107	9,763.75	488.19	976.38	$1,229,535.37
Record mercury leaks l	0.25	365	91.25	7	638.75	31.94	63.88	$80,436.89
Record monitored parameters l	0.5	365	182.5	7	1,277.5	63.88	127.75	$160,873.79
Compile data for semiannual reports m	8	2	16	7	112	5.6	11.2	$14,104.00
Maintain data on mercury leaks n	0.5	52	26	7	182	9.1	18.2	$22,919.01
Maintain data on monitored parameters n	0.5	52	26	7	182	9.1	18.2	$22,919.01
E. Time to enter information
Records of startup, shutdown, and malfunction o	1.5	53.5	80.25	53.5	4,293.38	214.67	429.34	$540,658.70
F. Audits	N/A
Subtotal for Recordkeeping Requirements					18,917			$2,071,447
TOTAL LABOR BURDEN AND COSTS (rounded) p					20,600			$2,260,000
TOTAL CAPITAL AND O&M COST (rounded) p								$0
GRAND TOTAL (rounded) p								$2,260,000
Assumptions:
a We have assumed that there are approximately 107 existing sources currently subject to this rule. There will be no additional new source that will become subject to the rule over the three-year period of this ICR.
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 percent to account for the benefit packages available to those employed by private industry.
c We have assumed that it will take 1 hour for existing respondents to refamiliarize themselves with rule requirements.
d We have assumed that it will take each new respondent 24 hours to complete initial performance test. Since there are no new respondents estimated, this requirement does not apply.
e We have assumed that 20 percent of new respondents will repeat the performance test due to failure. Since there are no new respondents estimated, this requirement does not apply.
f We have assumed that each new respondent will take two hours to write notification reports on construction/reconstruction. Since there are no new respondents estimated, this requirement does not apply.
g We have assumed that it will take each new respondent two hours each to write notification reports on initial startup and actual startup. Since there are no new respondents estimated, this requirement does not apply.
h We have assumed that 100 of the existing respondents will take 12 hours to write reports on the annual emission tests.
i We have assumed that seven of the existing respondents will each have to submit semiannual reports.
j We have assumed that seven of the existing respondents will write notification reports on parameter excursions two times per year.
k We have assumed that all respondents will record operating parameters 365 days per year.
l We have assumed that seven respondents will each have to record mercury leaks and monitored parameters.
m We have assumed that seven respondents will each take eight hours to compile data for semiannual reports.
n We have assumed that each of the seven respondent will have to maintain data on mercury leaks and monitored parameters 52 times per year.
o We have assumed that 50 percent of the respondents will each take 1.5 hours to record information of startup, shutdown, and malfunctions.
p Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 2: Agency Burden

Table 2: Average Annual EPA Burden and Cost - NESHAP for Mercury (40 CFR Part 61, Subpart E) (Renewal)
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 hr/yr (E=CxD)	(F) Management person hr/yr (Ex0.05)	(G) Clerical person hr/yr (Ex0.1)	(H) Cost, $ b
Required activities
New Plants										Tech	$48.08
Initial performance test c	24	1	24	0	0	0	0	$0		Mgmt	$64.80
Repeat initial performance test c, d	24	0.2	4.8	0	0	0	0	$0		Cler	$26.02
Report Review										Agency Rates Source: Office of Personnel Management (OPM), 2017 General Schedule
New Plants											Hourly Mean Wage	With Fringe & Overhead
Notification of construction e	0.5	1	0.5	0	0	0	0	$0		(GS- 12, step 1) - Tech.	30.05	$48.08
Notification of initial startup e	0.5	1	0.5	0	0	0	0	$0		(GS- 13, step 5) - Mgmt.	40.5	$64.80
Notification of actual startup e	0.5	1	0.5	0	0	0	0	$0		(GS-6, step 3) - Cler.	16.26	$26.02
Notification of initial test e	0.5	1	0.5	0	0	0	0	$0
Review test results f	8	1.2	9.6	0	0	0	0	$0
Existing Plants
Annual emission test	4	1	4	100	400	20	40	$21,568.64
Review semiannual reports g	8	2	16	7	112	5.6	11.2	$6,039.22
Review notification on monitored parameters h	8	2	16	7	112	5.6	11.2	$6,039.22
TOTAL ANNUAL BURDEN AND COST i					718			$33,600
a We have assumed that there are approximately 107 existing sources currently subject to this rule. There will be no additional new sources that will become subject to the rule over the three-year period of this ICR.
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 for Managerial (GS-13, Step 5), $48.08 for Technical (GS-12, Step 1), and $26.02 Clerical (GS-6, Step 3). 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 Agency will take 24 hours to participate in the performance tests. It is assumed that all initial performance tests have been completed by existing respondents. Since there are no new respondents estimated, this requirement does not apply.
d We have assumed that 20 percent of new respondents will have to repeat the performance tests due to failure. Since there are no new respondents estimated, this requirement does not apply.
e We have assumed that it will take 0.5 hours for the Agency to review notification reports for each respondent. Since there are no new respondents estimated, this requirement does not apply.
f We have assumed that it will take 8 hours for the Agency to review test results for each respondent. Since there are no new respondents estimated, this requirement does not apply.
g We have assumed that seven of the existing respondents will each have to submit semiannual reports, and the Agency will take eight hours two times per year to review each report.
h We have assumed that seven respondents will each have to record mercury leaks and monitored parameters, and the Agency will take eight hours each to review each notification.
i Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.