Burden Calculation Tables

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Overview

Respondents
Responses
Respondent Burden
Agency Burden
Capital & O&M

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Sheet 1: Respondents

Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
	(A)	(B)	(C)	(D)	(E)
Year	Number of New Respondents	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	0.33	12	0	0	12.3
2	0.33	12.3	0	0	12.7
3	0.33	12.7	0	0	13.0
Average	0.33	12.3	0	0	12.7

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Sheet 2: Responses

Total Annual Responses
(A) Information Collection Activity	(B) Number of Respondents	(C) Number of Responses	(D) Number of Existing Respondents That Keep Records But Do Not Submit Reports	(E) Total Annual Responses E=(BxC)+D
Initial notification	0.33	1	0	0.33
Notification of compliance status	0.33	1	0	0.33
Request for extension of compliance	0.33	1	0	0.33
Notification of special compliance requirements	0.33	1	0	0.33
Notification of initial performance test	0	1	0	0
Additional notification requirements for sources with CMS	0	1	0	0
Notification of adjustments to time periods	0.33	1	0	0.33
Notification of changes to information provided	0.33	1	0	0.33
30-day notification of excess emissions	0.33	1	0	0.33	Added burden item because this is an existing requirement for new sources only that was missing in the last ICR table.
Initial performance test report	0	1	0	0
Inspection and monitoring plan	0.33	1	0	0.33
Annual report	0.33	1	0	0.33	Revised from semiannual to annual per RTR. Does not apply to existing sources.
Annual excess emissions report	0.33	1	0	0.33	Revised from semiannual to annual per RTR. Does not apply to existing sources.
Initial report on compliance approach	0.33	1	0	0.33
			Total	3.6
CMS - Continuous Monitoring System			hrs/response:	4.4
Assumes the new/reconstructed source to demonstrate compliance using the HAP fraction emitted standard, utilizing a combination of pretreatment and wastewater treatment plant modifications to achieve this performance standard. This compliance option does not require performance testing or a CMS.

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Sheet 3: Respondent Burden

Table 1: Annual Respondent Burden and Cost – NESHAP for Publicly Owned Treatment Works (40 CFR Part 63, Subpart VVV) (Renewal)										Source Type	No.
										Existing	12.0
				Tracy Curtis: Labor rates have been updated to reflect that these are publically owned facilities. Labor Rates:	$48.08	$64.80	$26.02			New (other sectors)	0.33
Burden item	A	B	C	D	E	F	G	H
	Person-hours per occurrence	Annual occurrences per respondent	Person-hours per respondent per year (AxB)	Respondents per year a	Technical hours per year (CxD)	Management hours per year (Ex0.05)	Clerical hours per year (Ex0.10)	Annual cost ($) b				Agency Rates Source: Office of Personnel Management (OPM), 2017 General Schedule
1. Applications	N/A											Labor Type	Total Compensation ($/hr)	Loaded Rate (Rate + 110%rate)
2. Surveys and studies	N/A											(GS- 13, step 5) - Mgmt.	40.5	$64.80
3. Reporting requirements												(GS- 12, step 1) - Tech.	30.05	$48.08
A. Familiarization with regulatory requirements c	0.5	1	1	12	6	0.3	0.6	$323.53				(GS-6, step 3) - Cler.	16.26	$26.02
B. Required activities
Initial notification d	2	1	2	0.33	0.66	0.03	0.07	$35.50
Notification of compliance status d	2	1	2	0.33	0.66	0.03	0.07	$35.50
C. Create information	See 3B
D. Gather existing information	See 3B
E. Write reports
Request for extension of compliance	2	1	2	0.33	0.66	0.03	0.07	$35.50
Notification of special compliance requirements	2	1	2	0.33	0.66	0.03	0.07	$35.50
Notification of initial performance test d	N/A
Additional notification requirements for source with CMS d	N/A
Notification of adjustments to time periods	2	1	2	0.33	0.66	0.03	0.07	$35.50
Notification of changes to information provided	2	1	2	0.33	0.66	0.03	0.07	$35.50
30-day notification of excess emissions d	1	1	1	0.33	0.33	0.02	0.03	$17.94
Initial performance test report d	N/A
Inspection and monitoring plan d	2	1	2	0.33	0.66	0.03	0.07	$35.50
Annual report d	1	1	1	0.33	0.33	0.02	0.03	$17.94
Annual excess emissions report d	2	1	2	0.33	0.66	0.03	0.07	$35.50
Initial report on compliance approach d, e	2	1	2	0.33	0.66	0.03	0.07	$35.50
Reporting Subtotal					14.5			$678.91
4. Recordkeeping
A. Familiarization with regulatory requirements	See 3A
B. Plan activities	See 3E
C. Implement activities	See 3E
D. Develop record system	See 3E
E. Time to enter information
Records of annual inspections d	2	1	2	0.33	0.66	0.03	0.07	$35.50
Records of inspections, defects, and repair delays d	2	1	2	0.33	0.66	0.03	0.07	$35.50
F. Time to transmit or disclose information	N/A
G. Time to train personnel	N/A
H. Time for audits	N/A
Recordkeeping Subtotal					1.5			$71.00
TOTAL LABOR BURDEN AND COSTS (rounded)f					16			$750
TOTAL CAPITAL AND O&M COSTS (rounded)f								$0
GRAND TOTAL (rounded)f								$750
CMS - Continuous Monitoring System
N/A - Not Applicable
Assumptions:
a EPA estimates 12 existing sources and one new/reconstructed source will be subject to the standard over the three-year period of this ICR.
b This ICR uses the following labor rates for publicly owned facilities: $48.08 (technical), $64.80 (managerial), and $26.02 (clerical). These rates are from the Office of Personnel Management (OPM), 2017 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 This burden represents the time existing respondents spend familiarizing themselves with the regulatory requirements.
d New sources must install covers and controls, or comply with the HAP fraction emitted standard. Assumes one new/reconstructed source will demonstrate compliance using the HAP fraction emitted standard over the next three years, utilizing a combination of pretreatment and wastewater treatment plant modifications to achieve this performance standard. This compliance option does not require performance testing or a CMS, but does require initial notifications, monitoring, recordkeeping and reporting.
e The NESHAP specifies that existing facilities are subject to the initial report; however, all existing facilities previously submitted the required information, so none will submit an initial report.
f Totals have been rounded to three significant digits. Figures may not add exactly due to rounding.

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Sheet 4: Agency Burden

Table 2: Average Annual EPA Burden and Cost – NESHAP for Publicly Owned Treatment Works (40 CFR Part 63, Subpart VVV) (Renewal)
				Labor Rates:	$48.08	$64.80	$26.02
Burden item	A	B	C	D	E	F	G	H
	EPA person-hours per occurrence	Annual occurrences per respondent	EPA person-hours per respondent per year (AxB)	Respondents per year a	Technical hours per year (CxD)	Management hours per year (Ex0.05)	Clerical hours per year (Ex0.10)	Annual cost ($) b			Agency Rates Source: Office of Personnel Management (OPM), 2017 General Schedule
Initial performance test c	N/A											Hourly Mean Wage	With Fringe & Overhead
Repeat initial performance test c	N/A										(GS- 12, step 1) - Tech.	30.05	$48.08
Report review											(GS- 13, step 5) - Mgmt.	40.5	$64.80
Initial notification	2	1	2	0.33	0.66	0.03	0.07	$35.50			(GS-6, step 3) - Cler.	16.26	$26.02
Notification of compliance status c	2	1	2	0.33	0.66	0.03	0.07	$35.50
Request for extension of compliance	0.5	1	1	0.33	0.17	0.01	0.02	$9.34
Notification of special compliance requirements c	2	1	2	0.33	0.66	0.03	0.07	$35.50
Notification of initial performance test c	2	1	2	0	0	0	0	$0
Additional notification requirements for sources with CMS c	2	1	2	0	0	0	0	$0
Notification of adjustments to time periods c	2	1	2	0.33	0.66	0.03	0.07	$35.50
Notification of changes to information provided	2	1	2	0.33	0.66	0.03	0.07	$35.50
30-day notification of excess emissions	2	1	2	0.33	0.66	0.03	0.07	$35.50
Initial performance test report c	2	1	2	0	0	0	0	$0
Inspection and monitoring plan c	2	1	2	0.33	0.66	0.03	0.07	$35.50
Annual report c	1	1	1	0.33	0.33	0.02	0.03	$17.94	Revised to annual report. Not required of existing sources.
Annual excess emissions report c	1	1	1	0.33	0.33	0.02	0.03	$17.94	Revised to annual report. Not required of existing sources.
Initial report on compliance approach c	2	1	2	0.33	0.66	0.03	0.07	$35.50
TOTAL d					7			$329
CMS - Continuous Monitoring System
N/A - Not Applicable
Assumptions:
a EPA estimates 12 existing sources and one new/reconstructed source will be subject to the standard over the three-year period of this ICR.
b This ICR uses the following labor rates: $48.08 (technical), $64.80 (managerial), and $26.02 (clerical). These rates are from the Office of Personnel Management (OPM), 2017 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 Existing sources have no notification and reporting activities under this NESHAP and demonstrate compliance with the rule by operating treatment and control devices that meet all requirements specified in the appropriate industrial NESHAP(s). New sources are subject to rule emission limits, control requirements, and related performance testing, plan development, and reporting activities. There is one new source expected to be subject to these requirements over the three-year period of this ICR.
d Totals have been rounded to three significant digits. Figures may not add exactly due to rounding.

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Sheet 5: Capital & O&M

Capital/Startup vs. Operation and Maintenance (O&M) Costs

EPA expects the new/reconstructed source to demonstrate compliance using the HAP fraction emitted standard, utilizing a combination of pretreatment and wastewater treatment plant modifications to achieve this performance standard. No new control or monitoring equipment (CMS) is expected.