burden calculations

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Overview

Table 1
Table 2
Capital & O&M
Total Annual Responses
Respondents

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Sheet 1: Table 1

Table 1: Annual Respondent Burden and Cost – NSPS for Electric Utility Steam Generating Units (40 CFR Part 60, Subpart Da) (Renewal)
					121.46	148.45	60.23
Burden Item	A	B	C	D	E	F	G	H
	Person-hours per occurrence	No. of occurrences per respondent per year	Person-hours per respondent per year (C=AxB)	Respondents per year a	Technical hours per year (E=CxD)	Management hours per year (F=Ex0.05)	Clerical hours per year (G=Ex0.10)	Total cost per year ($) b
1. Applications	N/A
2. Survey and Studies	N/A
3. Reporting requirements
A. Familiarize with regulatory requirements c	1	1	1	732	732	36.6	73.2	$98,750.83
B. Required activities
Initial emissions tests	160	1	160	0	0	0	0	$0
Reference Method 9	4	30	120	0	0	0	0	$0
Repeat performance test d	60	0.2	12	0	0	0	0	$0
C. Create information	See 3B
D. Gather existing information	See 3E
E. Write report
Notification of construction/reconstruction	2	1	2	0	0	0	0	$0
Notification of actual startup	2	1	2	0	0	0	0	$0
Notification of initial performance test	2	1.2	2.4	0	0	0	0	$0
Notification of demonstration of CMS	2	1	2	0	0	0	0	$0
Report of performance test	See 3B
Semiannual report e	8	2	16	586	9,370	468	937	$1,264,010.57
Quarterly report f	8	4	32	146	4,685	234	468	$632,005.29
Subtotal for Reporting Requirements					17,004			$1,994,767
4. Recordkeeping requirements
A. Familiarize with regulatory requirements	See 3A
B. Plan activities	See 4C
Implement activities	See 3B
Develop record system	N/A
C. Time to check computer system and calibrate continuous monitor g	0.5	365	182.5	732	133,590	6,680	13,359	$18,022,025.75
D. Train personnel	N/A
E. Audits	N/A
Subtotal for Recordkeeping Requirements					153,629			$18,022,026		responses	hr/response
TOTAL LABOR BURDEN AND COSTS (rounded) h					171,000			$20,000,000		1,756	97
TOTAL CAPITAL AND O&M COST (rounded) h								$11,000,000
GRAND TOTAL (rounded) h								$31,000,000
Assumptions:
a We have assumed that there are an average of 732 existing respondents subject to the rule and no new sources that will become subject to the rule over the three-year period of this ICR.
b This ICR uses the following labor rates: $121.46 for technical, $148.45 for managerial, and $60.23 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 We have assumed that all respondents will have to familiarize with the regulatory requirements each year.
d We have assumed that 20 percent of initial performance tests will be repeated due to failure.
e We have assumed that 80 percent of respondents will each take 8 hours two times per year to write the semiannual report.
f We have assumed that 20 percent of respondents will each take 8 hours four times per year to write the quarterly report.
g We have assumed that each respondent will take 30 minutes each day to check computer system and calibrate continuous monitors.
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 Electric Utility Steam Generating Units (40 CFR Part 60, Subpart Da) (Renewal)
					50.72	68.37	27.46		<--Update Rates
Burden Item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Technical person-hours per occurrence	No. of occurrences per respondent per year	Technical person-hours per respondent per year (C=AxB)	Respondents per year a	Technical hours per year (E=CxD)	Management hours per year (F=Ex0.05)	Clerical hours per year (G=Ex0.10)	Total cost per year ($) b
Performance tests
New plants	24	1.2	28.8	0	0	0	0	$0
Review startup report c	40	1.2	48	0	0	0	0	$0
Report Review
Notification of construction/reconstruction	2	1	2	0	0	0	0	$0
Notification of actual startup	0.5	1	0.5	0	0	0	0	$0
Notification of initial test	0.5	1.2	0.6	0	0	0	0	$0
Notification of CMS demonstration	0.5	1	0.5	0	0	0	0	$0
Review excess emissions reports
Semiannual d	8	2	16	586	9,370	468.48	936.96	$532,985.01
Quarterly e	8	4	32	146	4,685	234.24	468.48	$266,492.51
TOTAL (rounded) f					16,200			$799,000
Assumptions:
a We have assumed that there are an average of 732 existing respondents subject to the rule and no new sources that will become subject to the rule over the three-year period of this ICR.
b This ICR uses the following labor rates: $50.72 for technical, $68.37 for managerial, and $27.46 for clerical labor. These rates are from the Office of Personnel Management (OPM) 2020 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 We have assumed that it will take 40 hours to review each startup report.
d We have assumed that it will take 8 hours two times per year to review each semiannual report.
e We have assumed that it will take 8 hours four times per year to review each the quarterly report.
f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: Capital & 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)
SO2, PM, and NOx	$200,000	0	$0	$15,000	732	$10,980,000
Total (rounded)			$0			$11,000,000

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Sheet 4: Total Annual Responses

Total Annual Responses
(A)	(B)	(C)	(D)	(E)
Information Collection Activity	Number of Respondents	Number of Responses	Number of Existing Respondents That Keep Records But Do Not Submit Reports	Total Annual Responses E=(BxC)+D
Notification of construction/ reconstruction	0	1	0	0
Notification of actual startup	0	1	0	0
Notify of initial performance test	0	1.2	0	0
Notification of demonstration of CMS	0	1	0	0
Semiannual report	586	2	0	1,172
Quarterly report	146	4	0	584
			Total	1,756

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Sheet 5: Respondents

OLD - From 1053.12
Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
	(A)	(B)	(C)	(D)	(E)
Year	Number of New Respondents 1	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	11	721	0	0	732
2	11	732	0	0	743
3	11	743	0	0	754
Average	11	732	0	0	743
For 1053.13 - Based on the average number of existing respondents from prior ICR, with no new respondents anticipated (reflects closures in industry)
Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
	(A)	(B)	(C)	(D)	(E)
Year	Number of New Respondents 1	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	732	0	0	732
2	0	732	0	0	732
3	0	732	0	0	732
Average	0	732	0	0	732