Burden Calculation Tables

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Overview

Table 1
Table 2
Capital and O&M

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Sheet 1: Table 1

Table 1: Annual Respondent Burden and Cost – NESHAP for Portland Cement Manufacturing Industry (40 CFR Part 63, Subpart LLL) (Renewal)
Burden Item	(A) Hours per Occurrence	(B) Occurrences/ Respondent/ Year	(C) Hours/ Respondent/ Year (A x B)	(D) Respondents/ Yeara	(E) Technical Hours/Year (C x D)	(F) Managerial Hours/Year (E x 0.05)	(G) Clerical Hours/Year (E x 0.10)	(H) Cost/ Yearb
1. APPLICATIONS	NA									Labor Rates:
2. SURVEY AND STUDIES	NA									Management	$147.40	These rates were updated 2/4/19 to match the United States Department of Labor, Bureau of Labor Statistics, June 2018, “Table 2. Civilian Workers, by occupational and industry group
3.ACQUISITION, INSTALLATION, AND UTILIZATION OF TECHNOLOGY AND SYSTEMS	16	1	16	0	0	0	0	$0		Technical	$117.92
4. REPORT REQUIREMENTS										Clerical	$57.02
A. Familiarize with regulatory requirement	1	1	1	40	40	2	4	$5,239.68
B. Required Activities											Number of kilns
New, Reconstructed, Modified Sources - Testing c										New	0
Initial PM Performance Test (kiln and cooler)	24	2	48	4	192	9.6	19.2	$25,150.46		Reconstructed/modified	4
Repeat PM Performance Test	24	2	48	0.2	10	0.48	0.96	$1,257.52		Existing	40
Initial D/F Performance Test (kiln)	8	1	8	4	32	1.6	3.2	$4,191.74
Repeat D/F Performance Test	8	1	8	0.2	2	0.08	0.16	$209.59
Initial THC/HAP Performance Test (kiln and dryer)	8	2	16	4	64	3.2	6.4	$8,383.49
Repeat THC/HAP Performance Test	8	2	16	0.2	3	0.16	0.32	$419.17
Initial Hg Performance Test (kiln)	8	1	8	4	32	1.6	3.2	$4,191.74
Repeat Hg Performance Test	8	1	8	0.2	2	0.08	0.16	$209.59
Initial HCl Performance Test (Method 321) (kiln)	8	1	8	4	32	1.6	3.2	$4,191.74
Repeat HCl Performance Test	8	1	8	0.2	2	0.08	0.16	$209.59
Initial Opacity Performance Test (mills)	8	1	8	4	32	1.6	3.2	$4,191.74
Repeat Opacity Performance Test	8	1	8	0.2	2	0.08	0.16	$209.59
Existing Sources - Annual Testing d
Annual PM Performance Test (kiln and cooler)	24	2	48	40	1,920	96	192	$251,504.64
Repeat PM Performance Test	24	2	48	2	96	4.8	9.6	$12,575.23
Annual Hg Performance Test (kiln)	8	1	8	40	320	16	32	$41,917.44
Repeat Hg Performance Test	8	1	8	2	16	0.8	1.6	$2,095.87
Annual HCl Performance Test (Method 321) (new, modified, reconstructed kilns)	8	1	8	40	320	16	32	$41,917.44
Repeat HCl Performance Test	8	1	8	2	16	0.8	1.6	$2,095.87
New and Existing Sources - Monitoring e
Daily Calibration Drift Tests - Hg CEMS	0.3	330	99	40	3,960	198	396	$518,728.32
Monthly Opacity Checks (Method 22) (mills)	0.5	12	6	40	240	12	24	$31,438.08
C. Create Information (Included in 4B)	See 4B
D. Gather Existing Information (Included in 4E)	See 4E
E. Write Report
New, Reconstructed, Modified Sources
Notification of construction/reconstruction	2	1	2	4	8	0.4	0.8	$1,047.94
Notification of actual startup	2	1	2	4	8	0.4	0.8	$1,047.94
Physical or Operational Change	2	1	2	4	8	0.4	0.8	$1,047.94
Notification of Demonstration of CEMS	2	1	2	4	8	0.4	0.8	$1,047.94
Notification of Opacity Observations	2	1	2	4	8	0.4	0.8	$1,047.94
Notification of Initial Performance Test	2	1	2	4	8	0.4	0.8	$1,047.94
Report of Performance Tests	2	1	2	4	8	0.4	0.8	$1,047.94
Semi-Annual Reports	24	2	48	4	192	9.6	19.2	$25,150
Existing Sources
Notification of Demonstration of CEMS	2	1	2	40	80	4	8	$10,479.36
Notification of Annual Performance Test	2	1	2	40	80	4	8	$10,479.36
Report of Annual Performance Test Results	2	1	2	40	80	4	8	$10,479.36
Semi-Annual Reports	2	2	4	40	160	8	16	$20,958.72
Subtotal for Reporting Requirements					9,176			$1,045,211
5. RECORDKEEPING REQUIREMENTS
A. Familiarize with regulatory requirement	See 4A
B. Plan Activities	See 4B
C. Implement Activities	See 4B
D. Record Data	NA
E. Time to Transmit or Disclose Information
Existing Sources
Data Collection	0.1	330	33	40	1,320	66	132	$172,909.44
Records of Startups, Shutdowns, malfunctions, etc	0.1	330	33	40	1,320	66	132	$172,909.44
New Sources
Data Collection	1.5	330	495	0	0	0	0	$0
Records of Startups, Shutdowns, malfunctions, etc	0.1	330	33	0	0	0	0	$0
Coal mill parameter monitoring	2	4	8	0	0	0	0	$0
F. Time to Train Personnel	80	1	80	0	0	0	0	$0
G. Time for Audits	NA
Subtotal for Recordkeeping Requirements					3,036			$345,819
Total Labor Burden and Cost (rounded) f					12,200			$1,390,000		58	hr/response
Total Capital and O&M Cost (rounded) f								$4,730,000
Grand TOTAL (rounded) f								$6,100,000
a We have assumed that there are approximately 40 respondents operating kilns and that 10% of the existing facilities will have new construction/reconstruction.
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 New kilns test for PM, D/F, Hg, HCl, and THC or Total Organic HAP. New raw and finish mills test for opacity. New coolers test for PM. New dryers test for THC or Total Organic HAP. All times for testing include calibration of the CEMS, COMS, or CPMS (temperature, pressure drop, air flow rate, sorbent flow rate, activated carbon injection rate) monitors on this equipment. We have assumed that 5 percent of respondents would repeat initial performance test due to failure.
d The rule requires existing kilns re-test annually for PM and Hg. New kilns and kilns that were modified or reconstructed after the rule was promulgated must also re-test annually for HCl. All times for testing include calibration of the CEMS or CPMS (pressure drop, air flow rate, sorbent flow rate, activated carbon injection rate) monitors on this equipment. We have assumed that 5 percent of respondents would repeat annual performance test due to failure.
e Opacity checks are required monthly. Calibration drift checks on the air flow sensor on the Hg CEMS are performed daily.
f 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 - NESHAP for Portland Cement Manufacturing Industry (40 CFR Part 63, Subpart LLL) (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)			Labor Rates:
Initial performance tests c	24	1	24	4	96.0	4.8	9.6	$5,248.66		Management	$65.71	These rates were updated 2/4/19 to match the rates from the Office of Personnel Management (OPM), 2018 General Schedule.
Repeat performance test d	24	1	24	0	0	0	0	$0		Technical	$48.75
Report Review										Clerical	$26.38
Notification of construction	0.5	1	0.5	4	2.0	0.1	0.2	$109.35
Notification of actual startup	0.5	1	0.5	4	2.0	0.1	0.2	$109.35
Notification of performance test e	0.5	1.1	0.55	44	24.2	1.2	2.4	$1,323.10
Notification of Physical or Operational Change	0.5	1	0.5	4	2.0	0.1	0.2	$109.35
Review test results/CEMS Results e	8	1	8	44	352.0	17.60	35.20	$19,245.07
Review semi-annual summary report	8	2	16	40	640	32.0	64.0	$34,991.04
TOTAL (rounded) f					1,290			$61,100
Assumptions:
a We have assumed that there are approximately 40 respondents with kilns and that 10% of the existing facilities will be re-constructed or modified.
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 EPA personnel will attend the initial performance tests for facilities that are re-constructed or modified, but will not attend the annual performance tests for existing facilities.
d We have assumed that 5 percent of respondents would repeat performance test due to failure, but that EPA would not attend repeat performance tests.
e Modified or reconstructed facilities conduct initial testing, and existing facilities (kilns and coolers) conduct annual testing.
f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: Capital and O&M

NESHAP for Portland Cement Manufacturing Industry (40 CFR Part 63, Subpart LLL) (Renewal)
Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A)	(B)	(C)	(D)	(E)	(F)	(G)
Continuous Monitoring Device	Capital/Startup Cost for One Respondent	Number of New Respondents	Total Capital/Startup Cost, (B X C)	Annual O&M Costs for One Respondent	Number of Respondents with O&M	Total O&M, (E X F)
Continuous Emission Monitors	$604,456	0	$0	$116,459	40	$4,658,360
Initial CEMS testing	$131,222	0	$0
Flow monitoring device for coal mills	$35,780	0	$0	$2,589	26	$67,314
Coal mill testing	$50,800	0	$0
TOTAL			$0			$4,730,000
					Toal Capital and O&M	$4,730,000