Burden Calculation 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 Secondary Lead Smelters (40 CFR Part 60, Subpart L) (Renewal)
					117.92	147.4	57.02		<--updated labor rates
Burden Item	(A) Person Hours per Occurrence	(B) No. of Occurrences per Respondent	(C) Person-hours per respondent (C=AxB)	(D) Respondents per year a	(E) Technical person-hours per year (E=CxD)	(F) Management person-hours per year (F= Ex0.05)	(G) Clerical person-hours per year (G= Ex0.1)	(H) Costb, $
1. Applications	N/A
2. Survey and studies	N/A
3. Reporting Requirements
All Sources
a. Familiarize with Regulatory Requirements	1	1	1	12	12	0.6	1.2	$1,571.90	<-- updated respondents from 14 to 12
New Sources
b. Required activities
Initial performance tests	21	1	21	0	0	0	0	$0
Repeat of performance tests c	21	0.2	4.2	0	0	0	0	$0
Method 5 or 9 Testing	3	1.2	3.6	0	0	0	0	$0
c. Create information	See 3b
d. Gather existing information	See 3b
e. Write Report
Notification of construction/ reconstruction d	2	1	2	0	0	0	0	$0
Notification of initial startup d	2	1	2	0	0	0	0	$0
Notification of initial performance test e	2	1	2	0	0	0	0	$0
Report of initial performance test	See 3b
Notification of physical or operational change d	2	1	2	0	0	0	0	$0
Subtotal Reporting Requirements					14			$1,572
4. Recordkeeping Requirements
a. Familiarize with Regulatory Requirements	See 3a
b. Plan activities	See 3b
c. Implement activities	See 3b
d. Develop record system	N/A
e. Time to enter information
Records of startup, shutdown, and malfunctions (SSM) f	1.3	1	1.3	12	15.6	0.78	1.56	$2,043.48	<-- updated respondents from 14 to 12
f. Audits	N/A
Subtotal Recordkeeping Requirements					18			$2,043
TOTAL LABOR BURDEN AND COSTS (roundedg)					32			$3,620					3	hrs/response
TOTAL CAPITAL AND O&M COSTS (roundedg)								$0
GRANT TOTAL (roundedg)								$3,620
Assumptions
a We have assumed that the average number of respondents that will be subject to the rule will be 12. In addition to the 12 active facilities there is one inactive facility that has been idled since 2013. There will be no additional new source that will become subject to the rule over the three-year period of this ICR. We assume that each source subject to the standard will have to familiarize with the regulatory requirements each year. Since there are no new or modified/reconstructed facilities expected the notifications for construction, startup, initial performance tests, or physical or operational changes will not occur during this three-year ICR period.
b This ICR uses the following labor rates: $147.40 per hour for 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 We have assumed that 20 percent of respondents will have to repeat initial performance tests.
d We have assumed that each respondent will take two hours once per year to write a construction/reconstruction report.
e We have assumed that each respondent will take two hours once per year to write the initial performance test report.
f We have assumed that each respondent will be required to enter SSM information.
g 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 Secondary Lead Smelters (40 CFR Part 60, Subpart L) (Renewal)
					48.75	65.71	26.38		<--updated labor rates
Burden Item	(A) EPA person-hours per activity	(B) No. of occurences 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 (F= Ex0.05)	(G) Clerical person-hours per year (G= Ex0.1)	(H) Annual costs ($)b
Initial Performance Test
New Sources	21	1	21	0	0	0	0	$0
Repeat Performance Test
New Sources	21	0.2	4.2	0	0	0	0	$0
Report Review
New Sources
Notification of construction c	2	1	2	0	0	0	0	$0
Notification of initial startup d	0.4	1	0.4	0	0	0	0	$0
Notification of actual startup d	0.4	1	0.4	0	0	0	0	$0
Notification of initial test d	0.4	1	0.4	0	0	0	0	$0
Review Test results f	7	1	7	0	0	0	0	$0
TOTAL COSTS (roundedg)					0			$0
Assumptions
a We have assumed that the average number of respondents that will be subject to the rule will be 12. In addition to the 12 active facilities there is one inactive facility that has been idled since 2013. There will be no additional new source that will become subject to the rule over the three-year period of this ICR. Since there are no new or modified/reconstructed facilities expected the notifications for construction, startup, initial performance tests, and test results will not occur during this three-year ICR period.
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 We assumed that it will take two hours once per year to review a construction report.
d We assume that it will take 0.4 hours once per year to review a notification of startup or testing.
e We assume that it will take seven hours once per year to review test results.
g Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding