Burden Calculation Table

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Overview

Table 1
Table 2
O&M

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Sheet 1: Table 1

					121.46	60.23	148.45
Table 1 - Annual Respondent Burden and Cost – NESHAP for Manufacturing of Nutritional Yeast (40 CFR Part 63, CCCC) (Renewal)
Burden Item	(A) Respondent Hours per Occurrence (Technical hours)	(C) Number of Occurrences Per Respondent Per Year	(D) Technical Hours per Respondent Per Year (A X C)	(E) Number of Respondents Per Year	(F) Technical Hours per Year (D X E)	(G) Clerical Hours per Year (F X 0.1)	(H) Management Hours per Year (F X .05)	(I) Total Labor Costs Per Year b
1. Applications	NA
2. Surveys and Studies	NA
3. Reporting Requirements
A. Familiarization with the regulatory requirements a	15	1	15	4	60	6	3	$8,094
B. Required Activities
1. VOC CEMS c
a. Capital Cost	0	1	0	0	0	0	0	$0
b. Annualized Cost d	0	1	0	4	0	0	0	$0
2. Performance evaluation e	8	1	8	1.33	10.64	1	1	$1,435
a. CEMS RATA f	0	6.5	0	1.33	0	0	0	$0
3. Brew Ethanol Correlation	10	3	30	0	0	0	0	$0
C. Create Information	Inc. in 3B
D. Gather Information	Inc. in 3E
E. Report Preparation
1. Develop Performance Evaluation Plan	15	1	15	0	0	0	0	$0
2. Notification of Performance Evaluation	2	1	2	1.33	2.66	0	0	$359
3. Performance Evaluation Report	2	1	2	1.33	2.66	0	0	$359
4. Notification of Performance Test	2	1	2	0	0	0	0	$0
5. Notification of Compliance Status	4	1	4	0	0	0	0	$0
6. Semiannual Compliance Report	4	2	8	4	32	3	2	$4,317
Subtotal for Reporting Requirements					124			$14,564
4. Recordkeeping Requirements
A. Read Instructions	Inc. in 3.A
B. Implement Activities	NA
C. Develop Record System	NA
1. Compliance Calculation Tracking	20	1	20	0	0	0	0	$0
D. Record information
1. Performance Evaluations	2	1	2	1.33	2.66	0	0	$359
2. CEMS Measurements	0.5	350	175	4	700	70	35	$94,434
3. Compliance Calculation	4	12	48	4	192	19	10	$25,902
4. CEMS Calibration and Maintenance	Inc. in 3.B.1.b
5. Store, File, and Maintain Records	12	1	12	4	48	5	2	$6,475
6. Retrieve Records/Reports	20	1	20	4	80	8	4	$10,792
E. Personnel Training
1. Acquisition, Installation, & Training	20	1	20	4	80	8	4	$10,792
2. CEMS Inspection and Monitoring	4	1	4	4	16	2	1	$2,158
F. Time for Audits	NA
Subtotal for Recordkeeping Requirements					1286			$150,913
TOTAL LABOR BURDEN AND COSTS (rounded) g					1410			$165,000		59	hrs/response
TOTAL CAPITAL AND O&M COST (rounded) g								$776,000
GRAND TOTAL (rounded) g								$941,000
Assumptions:
a We have assumed that all of the respondents will familiarize with the regulatory requirements each year.
b This ICR uses the following labor rates: $148.45 per hour for Executive, Administrative, and Managerial labor; $121.46 per hour for Technical labor, and $60.23 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2020, 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 facilities must use VOC CEMS.
d Annualized cost equals the average of all facility annualized costs (based on number of fermenters). Includes operation, maintenance, and repairs of CEMS.
e Labor hours to conduct performance evaluation of CEMS. Assumes 4 respondents will complete over 12 quarters or 3 years for average of 1.33/year.
f Line item for annual non-labor cost to conduct RATA. Number of occurrences per respondent equals the average number of CEMS (i.e., fermenters) per facility. Assumes 4 sources will complete over 12 quarters or 3 years for average of 1.33/year.
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

							50.72	68.37	27.46
Table 2 - Average Annual EPA Burden and Cost – NESHAP for Manufacturing of Nutritional Yeast (40 CFR Part 63, CCCC) (Renewal)
					(A)	(B)	(C)	(D)	(E)	(F)	(G)
Burden Item					Number of Occurrences Per Year a	Technical Hours Per Occurrence	Tech Hours Per Year (C=A x B)	Management Hours Per Year (D = C x 0.05)	Clerical Hours Per Year (E = C x 0.1)	Total Hours Per Year (C+D+E)	Total Cost Per Year c
1.	Applications				not applicable
2.	Familiarization with the regulatory requirements				0	20	0	0	0	0	$0
3.	Required Activities
	A.	Observe stack tests			0	16	0	0	0	0	$0
	B.	Excess emissions -- Enforcement Activities b			0	24	0	0	0	0	$0
	C.	Create Information			not applicable
	D.	Gather Information			not applicable
	E.	Report Reviews
		1.	Review performance evaluation plans		0	10	0	0	0	0	$0
		2.	Review performance evaluation reports		1.33	5	7	0	1	8	$378
		3.	Review performance test reports		0	5	0	0	0	0	$0
		4.	Review compliance reports		4	5	20	1	2	23	$1,138
	F.	Prepare annual summary report			1	10	10	1	1	12	$569
4.	Travel expenses: (1 person * 30 hours per year / 8 hours per day * $75 per diem) + ($600 per round trip) =							$0	per trip		$0
	TOTAL (rounded) d						42				$2,080
Assumptions:
	a Number of occurrences is the number of states where affected sources will exist and each EPA Region (3 states + 3 EPA regions = 6 respondents).
	b Assume 1 of the facilities will exceed emissions in year 2.
	c This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: $68.37 for Managerial (GS-13, Step 5, $42.73 x 1.6), $50.72 for Technical (GS-12, Step 1, $31.70 x 1.6), and $27.46 for Clerical (GS-6, Step 3, $17.16 x 1.6). These rates are from the Office of Personnel Management (OPM) 2020 General Schedule which excludes locality rates of pay.
	d Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
																				Percent of Stack Tests Observed			20%
																				Estimated Percent Retesting			10%
																				Estimated Percent Emission Exceedences			10%

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Sheet 3: O&M

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)
VOC CEMsa	$86,770	0	$0	$186,860	4	$747,440
CEMS RATAb	$0	0	$0	$21,216	1.33	$28,217
Brew Ethanol Correlationc	$0	0	$0	$19,500	0	$0
Total			$0			$776,000
a Assumes all facilities have installed CEMS to comply with the rule. Annual costs include operation, maintenance, and repair of CEMS.
b Assumes an annual O&M cost of $3,624 to conduct RATA per CEMS and an average of 6.5 CEMs per facility. Assumes 4 respondents will complete over 12 quarters or 3 years for average of 1.33 respondents/year.
c Assumes no facilities will conduct brew ethanol correlation.