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 Lead-Acid Battery Manufacturing (40 CFR Part 60, Subpart KK) (Renewal)
					117.92	147.4	57.02
Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (AxB)	(D) Respondents per year a	(E) Technical person- hours per year (CxD)	(F) Management person hours per year (Ex0.05)	(G) Clerical person hours per year (Ex0.1)	(H) Total Cost Per year b
1. Applications	N/A
2. Survey and Studies	N/A
3. Reporting Requirements
A. Familiarization with the regulatory requirements	1	1	1	52	52	2.6	5.2	$6,812
B. Required Activities
New Sources
Initial performance test c	20.87	1	20.87	0	0	0	0	$0
Repeat performance test d	20.87	1	20.87	0	0	0	0	$0
New and Existing Sources
Monitoring of emissions and operations	See 4E
C. Create information	See 3B
D. Gather existing information	See 3E
E. Write Report
New Sources
Notification of construction/reconstruction/modification	1.74	1	1.74	0	0	0	0	$0
Notification of initial startup	1.74	1	1.74	0	0	0	0	$0
Notification of CMS demonstration	1.74	1	1.74	0	0	0	0	$0
Notification of initial performance test	1.74	1	1.74	0	0	0	0	$0
Report of performance test	See 3B
New and Existing Sources
Semiannual reports e	13.91	2	27.82	13	361.66	18.08	36.17	$47,374.57
Subtotal for Reporting Requirements					476			$54,186.15
4. Recordkeeping requirements
A. Familiarization with the regulatory requirements	See 3A
B. Plan activities	See 4E
C. Implement Activities	See 4E
D. Develop record system	N/A
E. Time to enter information
Records monitoring of emissions and operations f	0.64	365	233.6	13	3,036.8	151.84	303.68	$397,796.51
Records of startups, shutdowns, malfunctions, etc. g	1.3	1	1.3	52	67.6	3.38	6.76	$8,855.06
F. Train Personnel	N/A
G. Audits	N/A
Subtotal for Recordkeeping Requirements					3,570			$406,651.56
TOTAL LABOR BURDEN AND COST (rounded) h					4,050			$461,000				62	hrs per response
TOTAL CAPITAL AND O&M COSTS (rounded): h								$11,700
GRAND TOTAL: h								$473,000
Assumptions:
a We have assumed that there are approximately 52 sources currently subject to NSPS, subpart KK. We have assumed that there will be no new sources over the period of this ICR. Therefore, the average number of respondents per year is estimated to be 52.
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, September 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 All sources are required to use Method 9 for opacity observations, except for lead oxide manufacturing facilities. All respondents would have to perform Method 12 to calculate the lead concentration and the volumetric flow rate of the effluent gases. It requires at least three runs of 60 minutes and 0.85 dscm.
d We have assumed that 20 percent of initial performance tests must be repeated due to failure.
e Semiannual reports are required by this rule for those sources that have to install continuous monitoring systems (e.g., pressure drop monitors across the scrubbing systems). We have assumed that 25% of the sources (i.e., 13 sources) have scrubbing systems.
f Monitoring of emissions and operations requirements includes pressure drop measurements across the scrubbing system at least every 15 minutes, if applicable. We have assumed that 25% of the sources (i.e., 13 sources) have scrubbing systems.
g We have assumed it will take 1.3 hours to record startup, shutdown, and malfunctions annually.
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 Lead-Acid Battery Manufacturing (40 CFR Part 60, Subpart KK) (Renewal)
					48.75	65.71	26.38
Activity	(A) EPA person- hours per occurrence	(B) No. of occurrences per plant per year	(C) EPA person- hours per plant per year (AxB)	(D) Plants per year a	(E) Technical person- hours per year (CxD)	(F) Management person-hours per year (Ex0.05)	(G) Clerical person-hours per year (Ex0.1)	(H) Cost, $ b
New Sources
Notification of construction/reconstruction	1.74	1	1.74	0	0	0	0	$0
Notification of initial startup	0.87	1	0.87	0	0	0	0	$0
Notification of CMS demonstration	0.87	1	0.87	0	0	0	0	$0
Notification of Initial Performance Test	0.43	1.2	0.52	0	0	0	0	$0
Initial Performance Test	20.87	1	20.87	0	0	0	0	$0
Repeat of Performance Test c	20.87	0.2	4.17	0	0	0	0	$0
Review Performance Test results c	6.96	1.2	8.35	0	0	0	0	$0
New and Existing Sources
Review of Semi-annual Reports d	2	1	2	13	26	1.3	2.6	$1,421.51
TOTAL COST (rounded) e					30			$1,420
Assumptions:
a We have assumed that there are approximately 52 sources currently subject to NSPS, subpart KK. We have assumed that there will be no new sources over the period of this ICR. Therefore, the average number of respondents per year is estimated to be 52.
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 for 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 20 percent of initial performance tests is typically repeated due to failure.
d We have assumed that 25 percent of the 52 existing sources (i.e., 13 sources) have scrubber systems and are therefore, required to install and maintain a monitor to measure and record pressure drop across the scrubbing system, and submit semi-annual reports.
e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.”