Burden Tables

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Overview

Table 1
Table 2
Additional
Total Annual Responses

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Sheet 1: Table 1

Table 1: Annual Respondent Burden and Cost – NSPS for Stationary Combustion Turbines (40 CFR Part 60, Subpart KKKK) (Renewal)
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 (F=Ex0.05)	(G) Clerical person hours per year (G=Ex0.1)	(H) Total Cost per year, $ b
1. Applications	N/A
2. Surveys and studies	N/A
3. Reporting requirements
A. Familiarization with Regulatory Requirements c	4	1	4	730	2,920	146.0	292.0	$382,496.64
B. Required activities
- Performance test d	12	1	12	199	2,388	119.4	238.8	$312,808.90
- Fuel sampling – dual fuel turbines e	0.5	52	26	106	2,756	137.8	275.6	$361,013.95
- Fuel sampling – distillate oil only turbines f	0.5	5	2.5	7	17.5	0.88	1.75	$2,292.36
C. Gather existing information	See 3D
D. Write report
Notification of construction/ reconstruction g, h	2	1	2	47	94	4.7	9.4	$12,313.25
Notification of actual startup g, h	2	1	2	47	94	4.7	9.4	$12,313.25
Notification of performance test d	2	1	2	199	398	19.9	39.8	$52,134.82
Notification of demonstration of CEMS i	2	1	2	15	30	1.5	3	$3,929.76
Initial notification of compliance g, h	2	1	2	47	94	4.7	9.4	$12,313.25
Semiannual Compliance report j, k	8	2	16	730	11,680	584	1168	$1,529,986.56
Subtotal for Reporting Requirements					23,542			$2,681,603
4. Recordkeeping requirements
A. Familiarization with Regulatory Requirement c	See 3A
B. Train personnel h	40	1	40	47	1,880	94	188	$246,264.96
C. Continuous monitoring
- Record information k, l	5	12	60	730	43,800	2,190	4,380	$5,737,449.60
Subtotal for Recordkeeping Requirements					52,532			$5,983,715
TOTAL LABOR BURDEN AND COST (rounded)m					76,100			$8,670,000
Captial and O&M Costm								$0
Grand Totalm								$8,670,000			42	hr/response
Assumptions:
a We have assumed that there is an average of 730 sources currently subject to the regulations, including 683 existing respondents, and an additional 47 respondents per year who will become subject to the standards. This ICR assumes the industry continues to grow at a constant rate since the previous renewal.
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 have assumed that it will take 4 hours for respondents to familiarize with regulatory requirements and that all sources will have to familiarize with requlatory requirements.
d We have assumed that 199 respondents will each take 12 hours to conduct annual stack testing to demonstrate compliance with NOx emission limitation.
e We have assumed that 106 respondents will each take 0.5 hours 52 times per year to complete fuel sampling for the dual fuel turbines.
f We have assumed that seven respondents will each take 0.5 hours 5 times per year to complete the fuel sampling for the distillate oil only turbines.
g We have assumed that it will take each new respondent 2 hours to write notification report.
h We have assumed that this is a one-time report for new respondents.
i We have assumed that of the 47 new respondents each year, 15 of these respondents will write reports demonstrating CEMS compliance.
j We have assumed that each of the respondents will take 8 hours twice per year to write the compliance report.
k The average number of existing respondents is 730.
l We have assumed that it will take each respondent 5 hours twelve times per year to record information.
m 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 Stationary Combustion Turbines (40 CFR Part 60, Subpart KKKK)(Renewal)
Activity	(A) EPA person- hours per occurrence	(B) No. of occurrences per plant per year	(C) EPA person- hours per plant per year (C=AxB)	(D) Plants 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) Cost, $ b
Report Review
1. Notification of construction/reconstruction c	1	1	1	47	47	2.35	4.7	$2,569.65
2. Notification of actual startup d	0.5	1	0.5	47	23.5	1.18	2.35	$1,284.83
3. Notification of performance test	2	1	2	199	398	19.9	39.8	$21,760.05
4. Notification of demonstration of CEMS e	2	1	2	15	30	1.5	3	$1,640.21
5. Initial notification of compliance	2	1	2	47	94	4.7	9.4	$5,139.31
6. Semiannual compliance report f	2	1	2	730	1460	73	146	$79,823.31
TOTAL ANNUAL BURDEN AND COST (rounded)g					2,360			$112,000
Assumptions:
a We have assumed that there is an average of 730 sources currently subject to the regulations and an additional 47 respondents per year will become subject. The ICR assumes the industry continues to grow at a constant rate since the previous renewal.
b This cost is based on the following hourly labor rates times a 1.6 benefits multiplication factor to account for government overhead expenses: $65.71 for Managerial, $48.75 for Technical, and $26.38 Clerical. These rates are from the Office of Personnel Management (OPM) “2018 General Schedule” which excludes locality rates of pay.
c We have assumed that new respondents will take one hour each to review the notification of construction/reconstruction report.
d We have assumed that it will take 0.5 hours for new respondents to review the actual startup report.
e We have assumed that of the 47 new respondents, only 15 of these respondents will review the notification of demonstration of CEMS report.
f We have assumed that it will take 2 hours once per year to review the compliance report.
g Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: Additional

2177.07
	Number of Respondents
		Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
		(A)	(B)	(C)	(D)	(E)
	Year	Number of New Respondents 1	Number of Existing Respondents	Number of Existing Respondents that keep records but do not submit reports	Number of Existing Respondents That Are Also New Respondents	Number of Respondents
						(E=A+B+C-D)
	1	47	636	0	0	683
	2	47	683	0	0	730
	3	47	730	0	0	777
	Average	47	683	0	0	730

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Sheet 4: Total Annual Responses

2177.06
	Total Annual Responses
	(A)	(B)	(C)	(D)	(E)
				Number of Existing Respondents That Keep Records But Do Not Submit Reports	Total Annual Responses
	Information Collection Activity	Number of Respondents	Number of Responses		E=(BxC)+D
	Notification of construction/reconstruction	47	1	0	47
	Notification of actual startup	47	1	0	47
	Notification of performance test	199	1	0	199
	Notification of demonstration of CEMS	15	1	0	15
	Initial notification of compliance	47	1	0	47
	Semiannual compliance report	730	2	0	1460
				Total	1,815