Burden Calculation Tables

---

Overview

Table 1
Table 2
Capital and O&M

---

Sheet 1: Table 1

Table 1: Annual Respondent Burden and Cost – NESHAP for Hydrochloric Acid Production (40 CFR Part 63, Subpart NNNNN) (Renewal)
					117.92	147.4	57.02		Update to 2018 labor rates (see updated template)
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) Cost, $ b
1. Applications	N/A
2. Survey and Studies	N/A
3. Reporting Requirements
A. Familiarize with rule requirements c	4	1	4	19	76	3.8	7.6	$9,955.39	Update to 19 respondents
B. Gather information c	4	1	4	0	0	0	0	$0	updated to 0 respondents
C. Write reports
Initial notification c	2	1	2	0	0	0	0	$0
Application for construction c	2	1	2	0	0	0	0	$0	updated to 0 respondents
Notification of intent to conduct performance test	2	1	2	0	0	0	0	$0	updated to 0 respondents
Notification of compliance status c	19.5	1	19.5	0	0	0	0	$0	updated to 0 respondents
First compliance report c, d	8.5	1	8.5	0	0	0	0	$0	updated to 0 respondents
Semiannual compliance report e	4.5	2	9	19	171	8.55	17.1	$22,399.63	Update to 19 respondents
Subsequent performance test reports f	4	1	4	0	0	0	0	$0	updated to 0 respondents
Startup, shutdown, malfunction report g	2	10	20	0	0	0	0	$0	updated to 0 respondents
Subtotal for Reporting Requirements					284			$32,355
4. Recordkeeping Requirements
A. Plan activities c, h	10	1	10	0	0	0	0	$0	updated to 0 respondents
B. Implement activities
Record startups, shutdown, malfunctions i	1	Tracy Curtis: Update to 10 10	10	19	190	9.5	19	$24,888.48	Update to 19 respondents, updated from 100 occurances to 10 occurances per year per insight from industry/OAQPS
Conduct performance test	48.5	1	48.5	19	921.5	46.08	92.15	$120,709.13	Update to 19 respondents
Record CPMS measurements j	1	365	365	19	6,935	346.75	693.5	$908,429.52	Update to 19 respondents
CMPS calibration and maintenance k	3.9	50	195	19	3,705	185.25	370.5	$485,325.36	Update to 19 respondents
Check for and repair leaks l	1	365	365	19	6,935	346.75	693.5	$908,429.52	Update to 19 respondents
C. Develop record system
Startup, shutdown, malfunction plan c	40	1	40	0	0	0	0	$0	updated to 0 respondents
Site-specific monitoring plan c	20	1	20	0	0	0	0	$0	updated to 0 respondents
Site-specific test plan c	20	1	20	0	0	0	0	$0	updated to 0 respondents
Leak detection and repair plan c	40	1	40	0	0	0	0	$0	updated to 0 respondents
D. Time to train personnel			0			0	0	$0	updated to 0 respondents
CPMS acquisition and installation c	20	1	20	0	0	0	0	$0	updated to 0 respondents
CPMS inspection and monitoring c	4	1	4	0	0	0	0	$0	updated to 0 respondents
E. Store, file, and maintain records m	20	1	20	19	380	19	38	$49,776.96	Update to 19 respondents
F. Retrieve records/reports n	20	1	20	19	380	19	38	$49,776.96	Update to 19 respondents
Subtotal for Recordkeeping Requirements					22,363			$2,547,336
TOTAL LABOR BURDEN AND COST (rounded) o					22,600			$2,580,000
Capital and O&M Cost o								$161,000	<--Updated this to reflect revised capital and O&M based on # of respondents (see new tab)
Grand TOTAL o								$2,740,000
										114	hr/resp
Assumptions:
a We have assumed that the average number of respondents that will be subject to the rule will be 19. There will be no additional new respondents that
will become subject to the rule over the three-year period of this ICR.
b This ICR uses the following labor rates: $147.40 per hour for Executive, Administrative, and Managerial labor; $117.92 per hour for Technical labor, and
$57.02 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2018, “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 each facility and only sources that started up prior to April 17, 2003 are required to submit initial notification
d Applies only to new respondents.
e We have assumed that it will take each respondent 4.5 hours two times per-year to prepare the semiannual compliance report.
f We have assumed that no facilities will perform tests after the initial compliance determination.					<-- Updated this footnote since we are using there are 0 new respondents.
g We have assumed that it will take each new respondents two hours ten times a year to prepare a SSM report. However, no new respondents are anticipated to become subject to the rule over the three-year period.
h We have assumed that it will take each new respondent 10 hours to record plan activities. However, no new respondents are anticipated to become subject to the rule over the three-year period.
i We have assumed that each respondent will have to implement SSM activities 10 times per-year.
j We have assumed that respondents will have to record CPMS measurements 365 time per year.
k We have assumed that respondents will have to implement CMPS calibration and maintenance activities 50 times per year.
l We have assumed that respondent are required to check for and repair leaks 365 times per-year.
m We have assumed that each respondent will take 20 hours once per-year to store, file and maintain records.
n We have assumed that it will take respondent 20 hours to retrieve records/reports once per-year.
o Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

---

Sheet 2: Table 2

Table 2: Average Annual EPA Burden and Cost – NESHAP for Hydrochloric Acid Production (40 CFR Part 63, Subpart NNNNN) (Renewal)
					48.75	65.71	26.38		Update to 2018 labor rates (see updated template)
Activity	(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) Cost, $ b
Review initial notification c	4	1	4	0	0	0	0	$0
Review application for construction c	4	1	4	0	0	0	0	$0	updated to 0 respondents
Review notification of intent to conduct test d	4	1	4	0	0	0	0	$0	updated to 0 respondents
Review notification of compliance status c	20	1	20	0	0	0	0	$0	updated to 0 respondents
Review first compliance report e	20	1	20	0	0	0	0	$0	Broke out over two lines. Prior ICR did not account for burden from the semiannual report for existing sources; have separated into first report (new sources) and existing sources.
Review semiannual compliance report e	20	2	40	19	760	38	76	$41,551.86	updated to 0 respondents
Review subsequent performance test report f	10	1	10	0	0	0	0	$0
Review startup, shutdown, malfunction report g	8	10	80	0	0	0	0	$0	updated to 0 respondents
Attend performance test	20	1	20	0	0	0	0	$0	updated to 0 respondents
TOTAL ANNUAL BURDEN AND COST (rounded) h					874			$41,600
									<-- need to discuss increase in 6(f). Prior ICR left out review of semiannual reports for existing sources.
Assumptions:
a We have assumed that the average number of respondents that will be subject to the rule will be 19. There will be two additional new sources per year 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:
Managerial rate of $65.71 (GS-13, Step 5, $41.07 x 1.6), Technical rate of $48.75 (GS-12, Step 1, $30.47 x 1.6), and Clerical rate of $26.38 (GS-6, Step 3,
$16.49 x 1.6). These rates are from the Office of Personnel Management (OPM) “2018 General Schedule” which excludes locality rates of pay.
c This is a one-time only activity for each facility and only sources that started up prior to April 17, 2003 are required to submit initial notification.
d We have assumed that each respondent will take 4 hours to review notification of intent to conduct test.
e We have assumed that each respondent will take 20 hours to review the first compliance report (applies only to new respondents) once per year and 20 hours to review the semiannual compliance report twice per year.										<-- Updated this footnote since there are 0 new respondents.
f We have assumed that no facilities will perform tests after the initial compliance determination.					<-- Updated this footnote since there are 0 new respondents.
g We have assumed that it will take each new respondents eight hours to review the SSM report.
h Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

---

Sheet 3: Capital and O&M

Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A)	(B)	(C)	(D)	(E)	(F)	(G)
Continuous Monitoring Device	Capital/Startup Cost for One Respondent	Number of New Respondents	Total Capital/Startup Cost, (B X C)	Annual O&M Costs for One Respondent	Number of Respondents with O&M	Total O&M,
						(E X F)
Continuous monitoring systems (CMS)	$712	2	$1,424	$8,473	19 (existing)	$160,987	Updated # respondents
	N/A	N/A	N/A	$16,385	0 (new)	$0	Updated # respondents
Total			$1,420			$161,000