burden calculations

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Overview

Table 1
Table 2
Capital and O&M
Respondents
Responses

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Sheet 1: Table 1

Table 1: Annual Respondent Burden and Cost – NSPS for Small Industrial-Commercial-Institutional Steam Generating Units (40 CFR Part 60, Subpart Dc) (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 person- hours per year (E=CxD)	Management person-hours per year (F=Ex0.05)	Clerical person-hours per year (G=Ex0.1)	Cost ($)b
1. Applications	N/A
2. Survey and Studies	N/A
3. Reporting requirements
A. Familiarize with the regulatory requirements c	2	1	2	323	646	32.3	64.6	$87,148.95
B. Required activities
Performance test (2.9 - 8.7 MW) h	8	2	16	7	112	5.6	11.2	$15,109.42
Performance test (8.7 – 29 MW) h	330	2	660	4	2,640	132	264	$356,150.52
C. Create information	See 3B
D. Gather existing information	See 3E
E. Write report
Notification of construction/reconstruction d, g	2	1.7	3.4	4	13.6	0.68	1.36	$1,834.71
Notification of modification e, g	2	1.7	3.4	7	23.8	1.19	2.38	$3,210.75
Notification of actual startup f, g	2	1.7	3.4	11	37.4	1.87	3.74	$5,045.47
Notification of initial performance test g	2	1.7	3.4	11	37.4	1.87	3.74	$5,045.47
Notification of demo of CEMS g	2	1.7	3.4	11	37.4	1.87	3.74	$5,045.47
Semiannual reports	16	2	32	323	10,336	516.8	1033.6	$1,394,383.25
Results of performance test	See 3B
Subtotal for Reporting Requirements					15,966			$1,872,974
4. Recordkeeping requirements
A. Familiarize with the regulatory requirements	See 3A
B. Plan activities	N/A
C. Implement activities	N/A
D. Develop record system	N/A
E. Check computer system, calibrate continuous monitors	1.5	365	547.5	323	176,843	8,842.1	17,684	$23,857,025.88
F. Train personnel	N/A
G. Audits	N/A
Subtotal for Recordkeeping Requirements					203,369			$23,857,026
TOTAL LABOR BURDEN AND COST (rounded) i					219,000			$25,700,000		responses	hr/response
TOTAL CAPITAL AND O&M COST (rounded) i								$12,600,000		721	304
GRAND TOTAL (rounded) i								$38,300,000
Assumptions:
a We have assumed that the average number of respondents that will be subject to the rule will be 312. There will be 11 additional new sources per year that will become subject to the rule over the three-year period of this ICR, for a total of 323 respondents.
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 We have assumed that existing respondents will have to familiarize with the regulatory requirements each year.
d We have assumed that four new respondents will each take two hours to write notification of construction/reconstruction report.
e We have assumed that seven new respondents will each take two hours to write notification of modification report.
f We have assumed that all new respondents will each take 16 hours to write the semiannual report two times per year.
g We have assumed that occurrences/respondents for new facilities are based on an average of 1.7 affected facilities per respondent, with an estimated 10 percent retest.
h This estimate includes performance test (opacity) for coal, wood, and oil-fired steam generating units and test of continuous emissions monitor.
i 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 Small Industrial-Commercial-Institutional Steam Generating Units (40 CFR Part 60, Subpart Dc) (Renewal)
					50.72	68.37	27.46
Activity	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	EPA person- hours per occurrence	No. of occurrences per plant per year	EPA person- hours per plant per year (C=AxB)	Plants per year a	Technical person- hours per year (E=CxD)	Management person-hours per year (F=Ex0.05)	Clerical person-hours per year (G=Ex0.1)	Cost b
Review of notification of construction/‌reconstruction c	2	1.7	3.4	4	13.6	0.68	1.36	$773.63
Review of notification of modification c	2	1.7	3.4	7	23.8	1.19	2.38	$1,353.85
Review of notification of actual startup c	2	1.7	3.4	11	37.4	1.87	3.74	$2,127.48
Review of initial CEMS demonstration c	2	1.7	3.4	11	37.4	1.87	3.74	$2,127.48
Review of demonstration of monitoring system c	2	1.7	3.4	11	37.4	1.87	3.74	$2,127.48
Review of semiannual reports d	8	2	16	323	5,168	258.4	516.8	$293,979.10
TOTAL ANNUAL BURDEN AND COST (rounded) e					6,120			$302,000
Assumptions:
a We have assumed that the average number of respondents that will be subject to the rule will be 312. There will be 11 additional new sources per year that will become subject to the rule over the three-year period of this ICR, for a total of 323 respondents.
b The cost is based on the following labor rate which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses. Managerial rates of $68.37 (GS-13, Step 5, $42.73 × 1.6), Technical rate of $50.72 (GS-12, Step 1, $31.70 × 1.6), and Clerical rate of $27.46 (GS-6, Step 3, $17.16 × 1.6). These rates are from the Office of Personnel Management (OPM) “2020 General Schedule” which excludes locality rates of pay.
c We have assumed that occurrences/respondent for new facilities are based on an average of 1.7 affected facilities per respondent.
d We have assumed that it will take 8 hours two times per year to review each semiannual report.
e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: Capital and 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 (BxC)	Annual O&M Costs for One Respondent	Number of Respondents with O&M	Total O&M,				New	Old
SO2 Monitoring										323.0	301.0
CEMS, control device inlet and outlet	$113,592	0	$0	$25,900	28	$725,200				521.1	485.7
CEMS, control device outlet only a	$73,028	19	$1,387,532	$17,100	521.0	$8,909,100				27.9	26.0
PM Monitoring										129.2	120.4
COMS for sources burning coal, residual oil, or wood b	$47,033	7	$329,231	$9,100	134	$1,219,400
TOTAL (rounded)			$1,720,000			$10,900,000
										$12,620,000
a Number of respondents with O&M (521 units) represents an annual average of 323 existing facilities, multiplied by an average of 1.7 affected units per facility, less an annual average of 28 units requiring inlet and outlet monitoring [301 x 1.7 = 549.1 - 28 = 521.1, rounded to 521 units]. Number of respondents with capital costs (19 units) represents an average of 11 new facilities per year, multiplied by an average of 1.7 affected units per facility [11 x 1.7 = 18.7, rounded to 19 units].
b Number of respondents with O&M (134 units) represents an annual average of 129.2 existing affected facilities that require COMS, plus an average of 4.4 new affected facilities per year that require COMS [129.2/323 × 11 = 4.4 new affected facilities per year that require COMS; 129.2 + 4.4 = 133.6, rounded to 134 facilities that require COMS] Number of respondents with capital costs (7 units) represents an average of 4.4 new affected facilities per year that require COMS, multiplied by an average of 1.7 affected units per facility [4.4 x 1.7 = 7.48, rounded to 7 units].
										2.5
										129.2
										4.4
										133.6

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Sheet 4: Respondents

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	301	0	0	312
2	11	312	0	0	323
3	11	323	0	0	334
Average	11	312	0	0	323

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Sheet 5: Responses

Total Annual Responses
(A)	(B)	(C)	(D)	(E)
			Number of Existing Respondents That Keep Records But Do Not Submit Reports	Total Annual Responses
Information Collection Activity	Number of Respondents	Number of Responses		E=(BxC)+D
	4	1.7	0	6.8
Notification of construction/ reconstruction
Notification of modification	7	1.7	0	11.9
Notification of actual startup	11	1.7	0	18.7
Notification of initial performance test	11	1.7	0	18.7
Notifications of CEMS demonstration	11	1.7	0	18.7
Semiannual compliance report	323	2	0	646
			Total	721