Burden Calculation Tables

Table 1: Annual Respondent Burden and Cost for Respondents – NESHAP for Engine Test Cells/Stands (40 CFR Part 63, Subpart PPPPP) (Amendments)
Burden item			Person hours per occurrence	No. of occurences 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
1. Applications			N/A									Technical	$112.98
2. Surveys and studies			N/A									Management	$149.35
3. Reporting requirements												Clerical	$54.81
	A. Familiarization with regulatory requirements a		4	1	4	8	32	1.6	3.2	$4,029.71
	B. Notifications c
		Initial notifications	2	1	2	1	2	0.1	0.2	$251.86
		Notification of construction/reconstruction	2	1	2	0.3	0.6	0.03	0.06	$75.56
		Notification of actual startup	2	1	2	0.3	0.6	0.03	0.06	$75.56
	C. Create information		See 3B
	D. Gather existing information		See 3E
	E. Write report
		Start-up Shutdown and Malfunction Plan d	N/A
		Compliance status report e	4	2	8	8	64	3.2	6.4	$8,059.42
		Performance evaluation report	16	1	16	0.3	4.8	0.2	0.5	$599.58
Subtotal for Reporting Requirements							120			$13,092
4. Recordkeeping requirements
	A. Initial performance evaluation f		330	1	330	0.3	99	5.0	9.9	$12,474.39
	B. Monitoring demonstration g		148	1	148	0.3	44.4	2.2	4.4	$5,586.05
	C. Repeat performance evaluation h		330	1	330	0	0	0	0	$-
	D. Maintain records of CEMS performance i		1.5	52	78	8	624	31.2	62.4	$78,579.38
Subtotal for Recordkeeping Requirements							883			$96,640
TOTAL LABOR BURDEN AND COST (rounded)j							1,000			$109,732
Total CAPITAL and O&M COST (rounded)j										$2,900
GRAND TOTAL (rounded)j										$112,632
Assumptions:
a We have assumed that the average number of respondents subject to the rule will be 8, and that one new facility will become subject to the emission limit, performance tests, monitoring, recordkeeping and reporting requirements of the rule over the three-year period of this ICR. This ICR assumes that all sources will incur a burden to re-familiarize themselves with the regulatory requirements each year.
b This ICR uses the following labor rates: $149.35 per hour for Managerial labor; $112.98 per hour for Technical labor, and $54.81 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2017, 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 there will be one new source subject to the initial notification requirements in each of the next three years and that one new source will be also subject to the notification of construction/reconstruction and notification of startup over the next three years.
d The one-time SSM plan is no longer be required.
e Compliance status reports are required semiannually. We have assumed that deviations get reported as part of the semiannual compliance status report.
f The technical persons-hours per occurrence were taken from the ESD manual Table 4 “Burden of Performance Tests and Continuous Monitoring System (CMS) Demonstrations” (Volume X, Section 2.2).
g Since there is only one new respondent subject to the e, we have assumed that it will not have to repeat the performance evaluations due to failure.
h We have assumed that owners and operators will maintain monitoring records on a weekly basis.
i We assume all of the recordkeeping and reporting burden from the rule at federal facilities will be conducted by federal employees.
j Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
Table 2: Average Annual EPA Burden and Cost - NESHAP for Engine Test Cells/Stands (40 CFR Part 63, Subpart PPPPP) (Amendments)
Burden item			EPA person hours per occurrence	No. of occurences 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
1. Attend initial performance evaluation			32	0.3	9.6	1	9.6	0.48	0.96	$517.65		Technical	$48.08
2. Repeat performance evaluation												Management	$64.80
	a. Retesting preparation		12	1	12	0	0	0	0	$-		Clerical	$26.02
	b. Attend retesting		32	1	32	0	0	0	0	$-
3. Deviation - enforcement activities c			16	1	16	1.6	25.6	1.3	2.6	$1,382.74
4. Reporting requirements
	a. Renew waivers d		2	2	4	0	0	0	0	$-
	b. Review reports
		Review initial notifications	2	1	2	1	2	0.1	0.2	$107.84
		Compliance status report e	2	2	4	8	32	1.6	3.2	$1,725.50
		Performance evaluation report	2	1	2	0.3	0.6	0.03	0.06	$32.35
Subtotals Labor Burden and Cost							69.8	3.51	7.02	$3,766.09
TOTAL ANNUAL BURDEN AND COST (rounded)f							80			$3,770
Assumptions:
a We have assumed that the average number of existing sources subject to the rule will be 7, and that one new facility will become subject to the rule over the three-year period of this ICR. That facility is not assumed to require repeat performance evaluation testing.
b This cost is based on the following hourly labor rates, increased by 60% to account for the benefit packages available to government employees: $64.80 for Managerial (GS-13, Step 5, $40.50+60%), $48.08 for Technical (GS-12, Step 1, $30.05 + 60%) and $26.02 Clerical (GS-6, Step 3, $16.26 + 60%). These rates are from the Office of Personnel Management (OPM) “2017 General Schedule” which excludes locality rates of pay.
c We have assumed that 20 percent of all respondents will be out of compliance.
d We have assumed that none of the respondents are submitting waivers for recordkeeping and reporting requirements.
e Compliance status reports review is required semiannually. We assumed that deviations get reported as part of the semiannual compliance status report.
f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.