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 Grain Elevators (40 CFR Part 60, Subpart DD) (Renewal)
Burden item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Person hours per occurrence	No. of occurrences per respondent per year	Person hours per respondent per year	Respondents per year a	Technical person- hours per year	Management person hours per year	Clerical person hours per year	Total Cost per year b
			(C=AxB)		(E=CxD)	(Ex0.05)	(Ex0.1)			Labor Rates:
1. Applications	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
2. Survey and Studies	N/A									Technical	$117.92
3. Reporting requirements										Clerical	$57.02
A. Read and understand rule requirement	1	1	1	200	200	10	20	$26,198
B. Required activities
Initial performance tests c	28	1	28	0	0	0	0	$0
Repeat performance tests d	28	0.2	5.6	0	0	0	0	$0
C. Create information	See 3B
D. Gather existing information	See 3B
E. Write report e
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 results	2	1	2	0	0	0	0	$0
Notification of repeat performance test results	See 3B
Report of performance test results	8	1.2	9.6	0	0	0	0	$0
Subtotal for Reporting Requirements					230			$26,198
4. Recordkeeping requirements
A. Read and understand rule requirement	See 3A
B. Plan activities	See 3B
C. Implement Activities	See 3B
D. Develop record system	N/A
E. Time to enter and transmit information
Records of startup, shutdown, malfunction f	1	1	1	200	200	10	20	$26,198
F. Time to train personnel	N/A
G. Time for audits	N/A
Subtotal for Recordkeeping Requirements					230			$26,198
Total Labor Burden and Costs (rounded) g					460			$52,000
Total Capital and O&M Cost (rounded) g								$0
GRAND TOTAL (rounded) g								$52,000		2.3
Assumptions:										hr/response
a We have assumed that there are approximately 200 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three years.
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 have assumed that it will take twenty-eight hours for each new respondent to perform the initial performance test.
d We have assumed that 20 percent of respondents would repeat performance test due to failure.
e Applies to new or reconstructed sources. There are no additional new or reconstructed sources anticipated to become subject to the rule over the next three years.
f We have assumed that each respondent will take one hour to record information on startup, shutdown, malfunction.
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 Grain Elevators (40 CFR Part 60, Subpart DD) (Renewal)
Activity	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	EPA person- hours per occurrence	No. of occurrences per plant per year	EPA person- hours per plant per year	Plants per year a	Technical person- hours per year	Management person-hours per year	Clerical person-hours per year	Cost, $ b
			(C=AxB)		(E=CxD)	(Ex0.05)	(Ex0.1)
Initial performance tests c	24	1	24	0	0	0	0	$0		Labor Rates:
Repeat performance test d	24	0.2	4.8	0	0	0	0	$0		Management	$65.71	These rates were updated 12/26/18 to match the rates from the Office of Personnel Management (OPM), 2018 General Schedule.
Report Review										Technical	$48.75
Notification of construction	2	1	2	0	0	0	0	$0		Clerical	$26.38
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
Total Annual Burden and Cost (rounded) e					0			$0
Assumptions:
a We have assumed that there are approximately 200 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three years.
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 have assumed that it will take twenty-four hours for each new respondent to perform the initial performance test.
d We have assumed that 20 percent of new respondents would repeat performance test due to failure.
e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.