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 Ammonium Sulfate Manufacturing Plants (40 CFR Part 60, Subpart PP) (Renewal)
Burden Items	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Respondent Hours per Occurrence	Number of Occurrences per Respondent per Year	Hours per Respondent per Year (A x B)	Number of Respondents per Year a	Technical Hours per Year (C x D)	Management Hours per Year (E x 0.05)	Clerical Hours per Year (Ex0.1)a	Total Labor Costs per Year, $b
1. Applications	N/A									Labor Rates:
2. Survey and Studies	N/A									Management	147.40	These rates were updated 12/26/18 to match the United States Department of Labor, Bureau of Labor Statistics, June 2018, “Table 2. Civilian Workers, by occupational and industry group
3. Reporting Requirements										Technical	117.92
A. Read and understand rule requirements c	1	1	1	2	2	0.1	0.2	$261.98		Clerical	57.02
New Sources
B. Required Activities
Initial performance test
Ref Method 9 tests d	29.7	4	118.8	0	0	0	0	$0
Ref Method 5 d	4	1	4	0	0	0	0	$0
Repeat performance test e	4	0.2	0.8	0	0	0	0	$0
Existing sources
Monitoring of operations and emissions	See 4E
C. Create Information	See 3B
D. Gather Existing Information	See 3E
E. Write Report
New Sources
Notification of construction/ reconstruction	2	1	2	0	0	0	0	$0
Notification of actual startup	2	1	2	0	0	0	0	$0
Notification of initial performance test	2	1	2	0	0	0	0	$0
Notification of demonstration of CMS	2	1	2	0	0	0	0	$0
Report of initial performance test	See 3B
Existing Sources
Notification of operational change	2	1	2	0	0	0	0	$0
Semiannual reports f	16	2	32	2	64	3.2	6.4	$8,383.49
Subtotal for Reporting Requirements					76			$8,645
4. Recordkeeping Requirements
A. Read and understand rule requirements	See 3A
B. Plan activities	See 3B
C. Implement activities	See 3B
D. Develop record system	N/A
E. Time to enter records of operating parameters g	0.25	365	91.25	2	182.5	9.13	18.25	$23,906.04
F. Audits	N/A
Subtotal for Recordkeeping Requirements					210			$23,906
Total Labor Burden and Costs (rounded) h					286			$32,600
Total Capital and O&M Costs (rounded) h								$0
Grand Total (rounded)h								$32,600
Assumptions:
a. We have assumed that there are approximately 2 respondents subject to the rule, with no new sources expected over the next three-years 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. We assumed that each respondent will spend one hour each year to read and understand the rule requirements.
d. As specified in the general provisions each performance test shall consist of three separate runs using the applicable test method. Sources are required to use Method 9 published in the 11th edition of the Official Methods of analysis of the Association of Official analytical Chemists dates 1970. Each run shall be conducted for the time and under the conditions specified in the applicable rule. The particulate matter concentration and volumetric flow rate of the effluent gas shall be determined by Method 5 which requires a sampling time and a sample volume for each run of at least 60 minutes and 1.50 dscm (53 dscf). Since there are no new respondents estimated, these requirements do not apply.
e. We assume that 20 percent of initial performance tests must be repeated due to failure. Since there are no new respondents estimated, these requirements do not apply.
f. We have assumed that it will take each respondent 16 hours twice per year to complete the semiannual reports.
g. Sources are required to maintain a daily record of operating parameters. We assume records will be recorded 365 days per year.
h. 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 Ammonium Sulfate Manufacturing Plants (40 CFR Part 60, Subpart PP) (Renewal)
Burden Items	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	EPA Hours per Occurrence	Occurrences per Plant per Year	EPA Hours per Plant per Year (AxB)	Plants per Year a	Technical EPA Hours per Year (CxD)	Managerial Hours per Year (Ex0.05)	Clerical Hours per Year (Ex0.1)	Cost per year, $b
Required Activities										Labor Rates:
New Plant										Management	65.71	These rates were updated 12/26/18 to match the rates from the Office of Personnel Management (OPM), 2018 General Schedule.
Initial performance tests c	24	1	24	0	0	0	0	$0		Technical	48.75
Repeat performance tests d	24	0.2	4.8	0	0	0	0	$0		Clerical	26.38
Report Review
New Plant
Notification of construction	2	1	2	0	0	0	0	$0
Notification of initial startup	0.5	1	0.5	0	0	0	0	$0
Notification of actual startup	0.5	1	0.5	0	0	0	0	$0
Notification of initial test	0.5	1.2	0.6	0	0	0	0	$0
Review test results	8	1.2	9.6	0	0	0	0	$0
Notification of demonstration of CMS	0.5	1	0.5	0	0	0	0	$0
Existing Plants
Semiannual reports e	8	2	16	2	32	1.6	3.2	$1,749.55
Total Annual Burden and Cost (rounded) f					37			$1,750
Assumptions:
a. We have assumed that there are approximately 2 respondents subject to the rule, with no new sources expected over the next three-years 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 + 60%), Technical rate of $48.75 (GS-12, Step 1, $30.47 + 60%), and Clerical rate of $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.
c. We assume that EPA personnel will attend initial performance tests.
d. We assume that 20 percent of initial performance test must be repeated due to failure.
e. We have assumed that it will take 8 hours to review each semiannual report.
f. Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.