Burden tables

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Overview

Breakdown
Industry (Private)
Industry (Public)
Agency

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Sheet 1: Breakdown

Category	Number of Respondents	Reporting Hours	Recordkeeping Hours	Total Respondent Labor Hours	Respondent Labor Cost	Capital & O&M Cost	Number of Responses
Private	19	75,951	8,653	84,600	$9,640,000	$857,000	49
State & Local Government	4	15,990	1,822	17,800	$850,000	$180,000	10
Total	23	92,000	10,000	102,000	$10,500,000	$1,040,000	59
							1,729	hrs/response

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Sheet 2: Industry (Private)

Burden item	(A) Person-hours per occurrence	(B) No. of occurrence per respondent per year	(C) Person-hours per respondent per year	(D) Respondents per yeara, b	(E) Technical person-hours per year	(F) Management person-hours per year	(G) Clerical person hours per year	(H) Cost $ c		Respondant Rates (Source: http://www.bls.gov/news.release/ecec.t02.htm)
			(C=AxB)		(E=CxD)	(Ex0.05)	(Ex0.1)			Labor Type	Total Compensation ($/hr)	Loaded Rate (Rate + 110%rate)
1. Applications	N/A									Mgmt.	$70.19	$147.40
2. Survey and Studies	N/A									Tech.	$56.15	$117.92
3. Reporting Requirements										Cler.	$27.15	$57.02
A. Familiarization with Regulatory Requirements	4	1	4	19	76	3.8	7.6	$9,954.97
B. Required Activities
i.  Initial performance tests and reports (PM, dioxins/furans, opacity, fugitives, HCl, Cd, Pb, Hg)	775	1	775	0	0	0	0	$0			2.35
ii. CEMS demonstration (SO2, NOx, opacity, CO, CO2, O2)											44.65
a. Installation of CEM units	225	1	225	0	0	0	0	$0
b. Initial demonstration	450	1	450	0	0	0	0	$0			9.4
iii. Annual performance tests and test reports (PM, dioxins/furans, opacity, fugitives, HCl, Cd, Pb, Hg)	775	1	775	19	14,725.00	736.25	1472.5	$1,928,775.48
iv. Quarterly Appendix F audits of CEMS (SO2, NOx, CO)
a. RATA audit (one per year) d	350	2.35	822.5	19	15,627.50	781.375	1,562.8	$2,046,990.75
b. RAA audit (three per year) e	130	7.05	916.5	19	17,413.50	870.68	1,741.4	$2,280,932.55
c. Daily calibration and operation f	1	858	858	19	16,302.00	815.1	1630.2	$2,135,341.11
C. Create Information	See 3B
D. Gather Information	See 3E
E. Report Preparation
i. Plant startup
a. Plant Control Plan	40	1	40	0	0	0	0	$0
b. Notification of Contract Awards	4	1	4	0	0	0	0	$0
c. Notification of on-site construction start	4	1	4	0	0	0	0	$0
d. Notification of construction completion	4	1	4	0	0	0	0	$0
e. Notification of final completion	4	1	4	0	0	0	0	$0
ii. Notification of initial performance tests	4	1	4	0	0	0	0	$0
iii. Initial compliance reports	40	1	40	0	0	0	0	$0
iv. Notification of CEMS demonstration	4	1	4	0	0	0	0	$0
v. Initial CEMS demonstration report	90	1	90	0	0	0	0	$0
vi. Annual compliance reports	40	2.3	92	19	1,748	87.4	174.8	$228,964.31
vii. Semiannual excess emission reports g	40	2	80	1.9	152	7.6	15.2	$19,909.94
Reporting Subtotal					75,951			$8,650,869
4. Recordkeeping Requirements
A. Familiarization with Regulatory Requirements	See 3A
B. Plan Activities	See 3B
C. Implement Activities	See 3B
D. Develop Record System	N/A
E. Record information
i. Record startups, shutdowns, and malfunctions h	4	47	188	19	3,572	178.6	357.2	$467,883.60
ii. Records of all emission rates, computations, tests h	4	47	188	19	3,572	178.6	357.2	$467,883.60
iii. Records of employee review of operations manual	4	1	4	19	76	3.8	7.6	$9,954.97
iv. Record amount of sorbent used for Hg and dioxin/furan control	4	4	16	19	304	15.2	30.4	$39,819.88
F. Personnel Training	N/A
G. Time for audits	N/A
Recordkeeping subtotal					8,653			$985,542
TOTAL LABOR BURDEN AND COST (Rounded):i					84,600			$9,640,000
Capital and O&M Cost (Rounded):i								$857,000
GRAND TOTAL (Rounded):i								$10,500,000
Assumptions:
a Assumes an average of 19 private respondents and 2.35 affected facilities (i.e., sources or units) per respondent [54 facilities at 23 plants; 54/23 = 2.35].
b No additional facilities will become subject to the standard over the next three years.
c 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 percent to account for the benefit packages available to those employed by private industry.
d Relative accuracy test audits (RATA) occur once per year for each affected facility (1 x 2.35 = 2.35). RATA are performed for one of the four quarterly audits. RAA tests are performed for three of the four quarterly audits. Audits of the diluent monitor (O2 or CO2) are not required because tests on SO2 and CO monitors will incorporate the use of the diluent monitor.
e Relative accuracy audits (RAA) occur three times per year for each affected facility (3 x 2.35 = 7.05).
f Daily calibration and operation data occurs daily [365 x 2.35 = 858 (Rounded)].
g Assumes 10 percent of private sources (1.9) have affected facilities with excess emissions and must submit two semiannual reports.
h Assumes 47 weeks of operation (90 percent availability) per year per facility.
i Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: Industry (Public)

Burden item	(A) Person-hours per occurrence	(B) No. of occurrence per respondent per year	(C) Person-hours per respondent per year	(D) Respondents per yeara, b	(E) Technical person-hours per year	(F) Management person-hours per year	(G) Clerical person hours per year	(H) Cost $ c		Source: http://www.opm.gov/oca/11tables/html/gs_h.asp
			(C=AxB)		(E=CxD)	(Ex0.05)	(Ex0.1)			Labor Type	Hourly Mean Wage	With Fringe & Overhead
1. Applications	N/A									(GS- 12, step 1) - Tech.	30.47	$48.75
2. Survey and Studies	N/A									(GS- 13, step 5) - Mgmt.	41.07	$65.71
3. Reporting Requirements										(GS-6, step 3) - Cler.	16.49	$26.38
A. Familiarization with Regulatory Requirements	4	1	4	4	16	0.8	1.6	$874.82
B. Required Activities
i.  Initial performance tests and reports (PM, dioxins/furans, opacity, fugitives, HCl, Cd, Pb, Hg)	775	1	775	0	0	0	0	$0
ii. CEMS demonstration (SO2, NOx, opacity, CO, CO2, O2)								$0
a. Installation of CEM units	225	1	225	0	0	0	0	$0
b. Initial demonstration	450	1	450	0	0	0	0	$0
iii. Annual performance tests and test reports (PM, dioxins/furans, opacity, fugitives, HCl, Cd, Pb, Hg)	775	1	775	4	3,100.00	155	310	$169,495.60
iv. Quarterly Appendix F audits of CEMS (SO2, NOx, CO)
a. RATA audit (one per year) d	350	2.35	822.5	4	3,290.00	164.5	329.0	$179,884.04
b. RAA audit (three per year) e	130	7.05	916.5	4	3,666.00	183.30	366.6	$200,442.22
c. Daily calibration and operation f	1	858	858	4	3,432.00	171.6	343.2	$187,648.03
C. Create Information	See 3B
D. Gather Information	See 3E
E. Report Preparation
i. Plant startup
a. Plant Control Plan	40	1	40	0	0	0	0	$0
b. Notification of Contract Awards	4	1	4	0	0	0	0	$0
c. Notification of on-site construction start	4	1	4	0	0	0	0	$0
d. Notification of construction completion	4	1	4	0	0	0	0	$0
e. Notification of final completion	4	1	4	0	0	0	0	$0
ii. Notification of initial performance tests	4	1	4	0	0	0	0	$0
iii. Initial compliance reports	40	1	40	0	0	0	0	$0
iv. Notification of CEMS demonstration	4	1	4	0	0	0	0	$0
v. Initial CEMS demonstration report	90	1	90	0	0	0	0	$0
vi. Annual compliance reports	40	2.3	92	4	368	18.4	36.8	$20,120.77
vii. Semiannual excess emission reports	40	2	80	0.4	32	1.6	3.2	$1,749.63
Reporting Subtotal					15,990			$760,215
4. Recordkeeping Requirements
A. Familiarization with Regulatory Requirements	See 3A
B. Plan Activities	See 3B
C. Implement Activities	See 3B
D. Develop Record System	N/A
E. Record information
i. Record startups, shutdowns, and malfunctions h	4	47	188	4	752	37.6	75.2	$41,116.35
ii. Records of all emission rates, computations, tests h	4	47	188	4	752	37.6	75.2	$41,116.35
iii. Records of employee review of operations manual	4	1	4	4	16	0.8	1.6	$874.82
iv. Record amount of sorbent used for Hg and dioxin/furan control	4	4	16	4	64	3.2	6.4	$3,499.26
F. Personnel Training	N/A
G. Time for audits	N/A
Recordkeeping subtotal					1,822			$86,607
TOTAL LABOR BURDEN AND COST (Rounded):					17,800			$850,000
Capital and O&M Cost (see Section 6(b)(iii)):								$180,000
TOTAL COST:								$1,030,000
Assumptions:
a Assumes an average of 4 public respondents and 2.35 affected facilities (i.e., sources or units) per respondent [54 facilities at 23 plants; 54/23 = 2.35].
b No additional facilities will become subject to the standard over the next three years.
c This ICR uses the following labor rates which incorporate a 1.6 benefits multiplication factor to account for government overhead expenses: $65.71 Managerial rate (GS-13, Step 5, $41.07 x 1.6), $48.75 Technical rate (GS-12, Step 1, $30.47 x 1.6), and $26.38 Clerical rate (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.
d Relative accuracy test audits (RATA) occur once per year for each affected facility (1 x 2.35 = 2.35). RATA are performed for one of the four quarterly audits. RAA tests are performed for three of the four quarterly audits. Audits of the diluent monitor (O2 or CO2) are not required because tests on SO2 and CO monitors will incorporate the use of the diluent monitor.
e Relative accuracy audits (RAA) occur three times per year for each affected facility (3 x 2.35 = 7.05).
f Daily calibration and operation data occurs daily [365 x 2.35 = 858 (Rounded)].
g Assumes 10 percent of public sources (0.4) have affected facilities with excess emissions and must submit two semiannual reports.
h Assumes 47 weeks of operation (90 percent availability) per year per facility.
i Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 4: Agency

Activity	(A) No. occurrence per year	(B) EPA person-hours per occurrence	(C) Technical person-hours per year	(D) Management person-hours per year	(E) Clerical person-hours per year	(H) Costa $		EPA Source: http://www.opm.gov/oca/11tables/html/gs_h.asp
			(C=AxB)	(Ex0.05)	(Ex0.1)				Hourly Mean Wage	With Fringe & Overhead
1. Applications	N/A							(GS- 13, step 5) - Mgmt.	41.07	$65.71
2. Report Reviews b, c								(GS- 12, step 1) - Tech.	30.47	$48.75
i.  Review preliminary and final material separation plans and siting analysis	0	8	0	0	0	$0		(GS-6, step 3) - Cler.	16.49	$26.38
ii. Review notification of construction	0	2	0	0	0	$0
iii. Review notification of startup	0	2	0	0	0	$0
iv. Review notification of initial performance test	0	8	0	0	0	$0
v. Review notification of initial CEMS demonstration	0	4	0	0	0	$0
vi. Review initial performance test report	0	40	0	0	0	$0
vii. Review initial CEMS demonstration report	0	40	0	0	0	$0
viii. Review annual compliance report d	23	92	2,116	105.8	211.6	$115,694.42
ix. Review semi-annual excess emission report e	4.6	16	73.6	3.68	7.36	$4,024.15
3. Prepare annual summary report	1	200	200	10	20	$10,935.20
TOTAL ANNUAL COST (rounded) f			2,750			$131,000
Assumptions:
a This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: $65.71 Managerial rate (GS-13, Step 5, $41.07 x 1.6), $48.75 Technical rate (GS-12, Step 1, $30.47 x 1.6), and $26.38 Clerical rate (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.
b No additional sources will become subject to the standard over the next three years. We also assume affected air quality program administrator in States and U.S. territories have already submitted a State Plan and/or negative declaration.
c Assumes 54 affected units at 23 plants.
d Assumes four hours to review the annual compliance report for each plant (4 x 23 = 92).
e Assumes submission of semiannual excess emission reports will be required for 10 percent of units (2.3); (2 x 2.3 = 4.6).
f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.