Burden Calculation Tables

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Overview

Industry
Agency
CAP&O&M

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Sheet 1: Industry

					121.46	148.45	60.23	Updated labor rates
Annual Respondent Burden and Cost (40 CFR Part 63 Subpart DDDDDD)
Burden Item	(A) Respondent Hours per Occurrence (Technical Hours)	(B) Number of Occurrences per Respondent per Year	(C) Hours per Respondent per Year (C = A x B)	(D) Number of Respondents per Year a	(E) Technical Hours per Year (E = C x D)	(F) Management Hours per Year (F = E x 0.05)	(G) Clerical Hours per Year (G = E x 0.1)	(H) Total Labor Costs per Year b
1. Applications	not applicable
2. Surveys and Studies	not applicable
3. Reporting Requirements
A. Familiarization with Regulatory Requirements c,d	21	1	21	3	63	3	6	$8,499
B. Required Activities
1) Periodic Performance Test, Sampling, and Report
a) Stripped Wastewater: TOHAP e	-8	12	-96	3	-288	-14	-29	-$38,853
b) Uncontrolled Wastewater: TOHAP e	-8	1	-8	3	-24	-1	-2	-$3,238
C. Create Information	Incl. in 3.B
D. Gather Information	Incl. in 3.E
E. Report Preparation	not applicable g
Subtotal for Reporting Requirements l						-286		-$33,591
4. Recordkeeping Requirements
A. Familiarization with Regulatory Requirements	Incl. in 3.A
B. Implement Activities	not applicable
C. Develop Record System	not applicable
D. Record Information
1) Records of Wastewater Requirements	-15	1	-15	3	-45	-2	-5	-$6,071
E. Personnel Training	Incl. in 3.B
F. Time for Audits	not applicable
Subtotal for Recordkeeping Requirements						-52		-$6,071
TOTAL LABOR BURDEN AND COSTS (rounded) r						-340		-$40,000
TOTAL CAPITAL AND O&M COST (rounded) r								-$21,000
GRAND TOTAL (rounded) r								-$61,000
Labor hours and costs shown as negative to reflect savings from no longer performing TOHAP wastewater testing.
a Assumes that, over the next three years, approximately 3 respondents per year will be subject to the standard, and no additional respondents per year will become subject to the standard.
b Labor rates are $148.45 for managerial, $121.46 for technical, and $60.23 for clerical. These rates from the United States Department of Labor, Bureau of Labor Statistics, September 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 percent to account for the benefit packages available to those employed by private industry.
c One-time only costs.
d Cost incurred by a facility regardless of the number of affected units at the plant.
e TOHAP Wastewater testing is estimated to take 4 hours per sample for 2 samples per facility. There is 1 wastewater stream per facility for area sources that is sampled monthly. There 1 uncontrolled wastewater stream per source that is sampled annually. See Capital/O&M costs for TOHAP samples.
f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
g The proposed rule revisions do not impact reporting requirements and thus no burden or burden reduction is shown for report preparation.

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Sheet 2: Agency

Annual EPA Burden and Cost (40 CFR Part 63 Subpart DDDDDD)
Burden Item	(A) EPA Person-Hours per Occurrence	(B) Number of Occurrences per Plant per Year	(C) EPA Person-Hours per Plant per Year (C = A x B)	(D) Plants per Year	(E) Technical Person-Hours per Year (E = C x D)	(F) Management Person-Hours per Year (F = E x 0.05)	(G) Clerical Person-Hours per Year (G = E x 0.1)	(H) EPA Total Cost per Year b
1. Applications	not applicable
2. Familiarization with Rule Requirements a	8	1	8	5	40	2	4	$2,275
3. Required Activities
A. Observe initial performance tests	48	1	48	0	0	0	0	$0
B. Excess emissions -- Enforcement Activities	24	1	24	0	0	0	0	$0
C. Create Information	not applicable
D. Gather Information	not applicable
E. Report Reviews	not applicable c
F. Prepare annual summary report d	24	1	24	0	0	0	0	$0
4. Travel expenses: (1 person * 30 hours per year / 8 hours per day * $75 per diem) + ($600 per round trip) =						n/a	per trip	$0
TOTAL ANNUAL BURDEN AND COST (rounded) e						46		$2,300
a Total Number of occurrences is the number of states and EPA Regions with affected sources (3 states + 2 EPA regions = 5 respondents). Assumed 8 hours per state and region to read and understand the rule requirements.
b Labor rates are $68.37 for managerial (GS-13, Step 5, $42.73 + 60%), $50.72 for technical (GS-12, Step 1, $31.70 + 60%), and $27.46 for clerical (GS-6, Step 3, $17.16 + 60%). These rates from the Office of Personnel Management (OPM), 2018 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 The proposed rule revisions do not impact reporting requirements and thus no burden or burden reduction is shown for report preparation.
d Using four hours per state (8 states) to write annual summary report.
e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: CAP&O&M

Capital/Startup vs. Operation and Maintenance (O&M) Costs
Capital/Startup/O&M Item	(A) Capital/Startup Cost for One Respondent	(B) Number of New Respondents	(C) Total Capital/Startup Cost (C = A x B)	(D) Annual O&M Costs for One Respondent	(E) Number of Respondents with O&M	(F) Total O&M (F = D x E)
Stripped Wastewater: TOHAP testing 1	$539	0	$0	-$6,465	3	-$19,394
Uncontrolled Wastewater: TOHAP testing 2	$539	0	$0	-$539	3	-$1,616
Total			$0			-$21,000
Note: Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
O&M costs shown as negative to reflect savings from no longer performing TOHAP wastewater testing.
1 Average cost for TOHAP testing is $538.72 per area source, and 1 test per area source per month.
2 TOHAP testing on uncontrolled streams is performed annually. There is 1 uncontrolled stream per facility.