Burden Calculations Table

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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 Coal Preparation and Processing Plants (40 CFR Part 60, Subpart Y) (Renewal)
					117.92	147.4	57.02
Burden Item	(A) Hours per Occurrence	(B) Occurrence per Respondent per Year	(C) Hours per Respondent per Year (C=AxB)	(D) Respondents per Year a	(E) Technical Hours per Year (E=CxD)	(F) Managerial Hours per Year (F=Ex0.05)	(G) Clerical Hours per Year (G=Ex0.1)	(H) Cost, ($) b
1. Applications	N/A
2. Survey and studies	N/A
3. Report Requirements
A. Familiarization with Regulatory Requirements c	2	1	2	757	1,514	75.7	151.4	$198,321.89
B. Required Activities
a. Initial Performance Testsi
Supervise Method 5 stack test performed by contractor service	8	1	8	0	0	0	0	$0
Supervise Method 9 opacity test performed by contractor service (except coal truck dumps)	2	1	2	0	0	0	0	$0
Supervise quarterly Method 9 opacity test performed by contractor service	4	1	4	0	0	0	0	$0
b. Repeat Performance Tests
Supervise Method 5 stack test performed by contractor service d
12-Month Testing	8	1	8	14.5	116	5.8	11.6	$15,195	<- assumes 50% of new (post-2009) respondents conduct 12-month PM testing
24-Month Testing	8	0.67	5	14.5	77	4	8	$10,130	<- assumes 50% of new (post-2009) respondents conduct 24-month PM testing
Supervise Method 9 opacity test performed by contractor service (except coal truck dumps) d, e	2	1	2	14.5	29	1.45	2.9	$3,799	<- assumes 50% of new (post-2009) respondents conduct 12-month opacity testing
Supervise quarterly Method 9 opacity test performed by contractor service d,e	4	3	12	14.5	174	8.7	17.4	$22,793	<- assumes 50% of new (post-2009) respondents conduct quarterly opacity testing
Supervise Method 9 opacity test performed by contractor service (coal truck dumps) f	2	0.6	1.2	4	4.8	0.24	0.48	$629	<- adds hours for coal truck dump Method 9 test every 5 years.
c. Compliance Monitoring and Inspection
Daily plant walkthrough visual observation of affected facilities for visible emissions d	1	350	350	14.5	5,075	253.75	507.5	$664,784.40	<- updated to 50% of 29 new respondents since 2009
Monthly visual inspection of control equipment used for affected facilities subject to opacity standards d	1	36	36	14.5	522	26.1	52.2	$68,377.82	<- updated to 50% of 29 new respondents since 2009
Coal handling affected facilities using fabric filter - inspect bag leak detectors (BLD) d	0.25	175	43.75	29	1,269	63.4375	126.875	$166,196.10	<--updated to 29 respondents
d. Site-specific Emission Control Plansi
Prepare "Fugitive Emission Control Plan"	40	1	40	0	0	0	0	$0
Prepare "BLD Monitoring Plan"	40	1	40	0	0	0	0	$0
e. Site-specific Emission Controls Operation Logbooki
Prepare logbook	8	1	8	0	0	0	0	$0
Record required emission control equipment operating and maintenance data	0.5	350	175	0	0	0	0	$0
C. Create Information	See 3B
D. Gather Existing Information	See 3E
E. Write Report
a. Notificationsi
Notification of construction/reconstruction commencement	2	1	2	0	0	0	0	$0
Notification of actual startup	2	1	2	0	0	0	0	$0
Notification of initial performance tests except coal dump trucks	2	8	16	0	0	0	0	$0
Notification of initial performance test for coal truck dumps	2	1	2	0	0	0	0	$0
Notification of repeat performance test except coal truck dumps	1	1	1	29	29	1.45	2.9	$3,799	<- updated to 29 respondents
Notification of repeat performance test for coal truck dumps	1	0.6	0.6	4	2.4	0.12	0.24	$314	<- added notifications for repeat performance tests for coal truck dumps
Notification of physical or operational change	2	1	2	0	0	0	0	$0
b. Reports
Performance test reports except coal truck dumps (review and transmit report prepared by test contractor)	4	6	23	29	657	33	66	$86,105	<- assumes 6 occurences per year from all testing under 3.B.b above.
Performance test reports for coal truck dumps (review and transmit report prepared by test contractor)	2	0.6	1.2	4	4.8	0.24	0.48	$629	<- assumes 0.6 occurences per year from all coal truck dump testing under 3.B.b above.
Semiannual excess emissions report h	8	2	16	757	12,112	605.6	1,211.2	$1,586,575.10
Subtotal for Reporting Requirements					24,824			$2,827,648
4. RECORDKEEPING REQUIREMENTS
A. Familiarization with Regulatory Requirements	See 3A
B. Plan Activities	See 3B
C. Implement Activities	See 3B
D. Record Data	See 3B
E. Time to Transmit or Disclose Information
Electronically transmit data j	1	12	12	757	9,084	454.2	908.4	$1,189,931.33
F. Time to Train Personnel
Plant personnel walkthrough observation procedure g	8	3	24	0	0	0	0	$0
G. Time for Audits	N/A
Subtotal for Recordkeeping Requirements					10,447			$1,189,931
Total Annual Labor Burden and Costs (rounded) k					35,300			$4,020,000
Captial and O&M Costs (rounded)k								$65,600
Grand Total (rounded)k								$4,090,000			20
											hr/response
Assumptions:
a We have assumed that the average number of sources that will be subject to the standard will be 757. There will be no additional new source per year 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 percent to account for the benefit packages available to those employed by private industry.
c We assume all respondents will take 2 hours to familiarize with the regulatory requirements.
d These requirements only apply to sources subject to the 2009 final rule amendment, i.e. sources constructed, reconstructed, or modified after April 28, 2008. EPA assumes that on average over the period covered under this ICR, there are 29 sources subject to the final rule amendment. EPA also assumes that 50 percent of sources will have a performance test that demonstrates that emissions from the affected facility are greater than 50 percent of the applicable emissions standard and a new performance test must be conducted within 12 calendar months. EPA assumes the remaining 50% of these facilities will conduct a repeat performance test within 24 months of prior test.
e EPA assumes that 50 percent of sources subject to the 2009 final rule amendment will elect to perform daily walk-through visual emission observations for compliance monitoring, and 50 percent of sources elect to perform repeat Method 9 opacity testing for compliance monitoring.
f These requirements only apply to coal truck dump operations subject to the 2009 final rule amendments. We assume that there are 4 such applicable operations following the 2009 final rule.
g We have assumed that each new respondent will take eight hours three time per year to observe procedures.
h All new and existing sources are subject to semiannual reporting.
i Initial requirements only apply to new sources
j We have assumed that each respondent will take one hour once per month to transmit electronic data.
k 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 Coal Preparation and Processing Plants (40 CFR Part 60, Subpart Y) (Renewal)
					48.75	65.71	26.38
Burden Item	(A) EPA Hours per Occurrence	(B) Occurrence per Plant per Year	(C) EPA Hours per Plant per Year (C=AxB)	(D) Plants per Year a	(E) Technical Hours per Year (E=CxD)	(F) Managerial Hours per Year (F=Ex0.05)	(G) Clerical Hours per Year (G=Ex0.1)	(H) Cost, ($) b
Notification Reviewc
Construction/reconstruction commencement notifications	1	1	1	0	0	0	0	$0
Actual startup notifications	1	1	1	0	0	0	0	$0
Performance test notifications	1	9	9	0	0	0	0	$0
Physical or Operational Change	1	1	1	0	0	0	0	$0
Site-Specific Emission Control Plan Reviewc
Review site-specific "Fugitive Emission Control Plan"	8	1	8	0	0	0	0	$0
Review site-specific "Bag Leak Detection Monitoring Plan"	8	1	8	0	0	0	0	$0
Compliance Demonstration Reports Review
Review performance test reports d	4	7	26.4	29	765.6	38.28	76.56	$41,858	<updates to 29 new (post-2009) respondents
Review semi-annual excess emissions reports e	4	2	8	757	6,056	302.8	605.6	$331,102.72
Coal Preparation Plant Site Visits
Observe Method 5 Performance Test	24	1	24	0	0	0	0	$0
Observe Method 9 Performance Test	24	1	24	0	0	0	0	$0
Total Annual Labor Burden and Costs (rounded) f					7,840			$373,000
Assumptions:
a We have assumed that the average number of sources that will be subject to the standard will be 757. There will be zero additional new source per year that will become subject to the rule over the three-year period of this ICR.
b This ICR uses the following labor rates: Managerial $65.71 (GS-13, Step 5, $41.07 + 60%); Technical $48.75 (GS-12, Step 1, $30.47 + 60%); and Clerical $26.38 (GS-6, Step 3, $16.49 + 60%). These rates are from the Office of Personnel Management (OPM), 2018 General Schedule, which excludes locality, rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees.
c Initial requirements only apply to new sources.
d We have assumed that 29 sources subject to the 2009 final rule are conducting repeat performance tests.
e We have assumed that all sources are subject to semiannual excess emissions reporting.
f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.