Burden Calculation Tables

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Overview

Table 1
Table 2

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Sheet 1: Table 1

Table 1: Annual Respondent Burden and Cost - NSPS for Calciners and Dryers in Mineral Industries (40 CFR Part 60, Subpart UUU) (Renewal)
					121.46	148.45	60.23
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 yeara	Technical person-hours per year (E=CxD)	Management person-hours per year (Ex0.05)	Clerical person-hours per year (Ex0.1)	Total Cost per yearb
1. Applications	N/A
2. Survey and Studies	N/A
3. Reporting Requirements
A. Familiarization with Regulatory Requirements c	1	1	1	167	167	8.35	16.7	$22,529.22
B. Required Activities
Initial performance test d	330	1	330	0	0	0	0	$0
Repeat performance test e	330	1	330	0	0	0	0	$0
Scrubber demonstration f	2	1	2	0	0	0	0	$0
Reference Method 9 text g,h	18	1	18	0	0	0	0	$0
Re-calibration of continuous opacity monitors (COM) i	4	2	8	0	0	0	0	$0
Re-calibration of scrubber i,j	4	2	8	0	0	0	0	$0
C. Create Information	See 3B
D. Gather existing information	See 3B
E. Write report
Notification of construction/reconstruction or modification	2	1	2	0	0	0	0	$0
Notification of actual startup	2	1	2	0	0	0	0	$0
Notification of demonstration of CMS	2	1	2	0	0	0	0	$0
Notification of physical or operation change k	2	1	2	1	2	0.1	0.2	$269.81
Notification of initial performance test	2	1	2	0	0	0	0	$0
Notification of repeat performance test	2	0.2	0.4	0	0	0	0	$0
Performance test report	8	1	8	0	0	0	0	$0
Semiannual reports l	16	2	32	167	5344	267.2	534.4	$720,934.99
Subtotal for Reporting Requirements					6,340			$743,734
4. Recordkeeping requirements
A. Familiarization with Regulatory Requirements c	See 3A
B. Plan activities	See 3B
C. Implement activities	See 3B
D. Develop record system	N/A
E. Time to enter information
Records of startup, shutdowns, malfunctions m	1.5	1	1.5	167	250.5	12.53	25.05	$33,793.83
F. Train to train personnel	N/A
G. Audits	N/A
Subtotal for Recordkeeping Requirements					288			$33,794
TOTAL LABOR BURDEN AND COST (rounded)n					6,630			$778,000
TOTAL CAPITAL AND O&M COST (rounded) n								$109,000			20	hr / response
GRAND TOTAL (rounded) n								$887,000
Assumptions:
a We have assumed that the average number of respondents that will be subject to the rule over the three-year period of this ICR will be 167. It is estimated that no additional respondents will become subject to the regulation in the next three years.
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 assume that each respondent will have to familiarize with the regulatory requirements each year.
d We have assumed that it will take 330 hours to complete a performance test.
e We have assumed that 20 percent of new respondents will have to conduct a CMS demonstration.
f We have assumed that 20 percent of new respondents will take two hours to conduct a scrubber demonstration.
g We have assumed that 80 percent of new respondents will conduct a reference Method 9 test.
h It will take respondents 18 hours to conduct a reference Method 9 test.
i It will take 4 hours to re-calibrate either the COM or the scrubber.
j We have assumed that 20 percent of new respondents will re-calibrate the scrubber.
k We have assumed that one respondent will notify the Agency regarding a physical or operational change.
l We have assumed that it will take 16 hours for each respondent to complete the semiannual report of exceedances.
m It will take each respondent 1.5 hours to record SSM information.
n 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 - NSPS for Calciners and Dryers in Mineral Industries (40 CFR Part 60, Subpart UUU) (Renewal)
					50.72	68.37	27.46
Burden item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Technical person hours per occurrence	Number of occurrences per year	Technical person hours per plant per year (C=AxB)	Plants per yeara	Technical hours per year (E=CxD)	Management hours per year (F=0.05xE)	Clerical hours per year (G=0.1xE)	Total Cost, per yearb
Initial performance tests
New or modified facility	40	1	40	0	0	0	0	$0
Repeat performance tests
New or modified facility	40	0.2	8	0	0	0	0	$0
Report review
New or modified facility
Modification of construction/reconstruction or modification	2	1	2	0	0	0	0	$0
Notification of actual startup	2	1	2	0	0	0	0	$0
Notification of demonstration of CMS	2	1	2	0	0	0	0	$0
Notification of physical or operational change c	2	1	2	1	2	0.1	0.2	$113.77
Notification of initial performance test	2	1	2	0	0	0	0	$0
Review demonstration of CMS d	4	1	4	0	0	0	0	$0
Review test results e	8	1.2	9.6	0	0	0	0	$0
Review of semiannual report of exceedances f	8	2	16	167	2672	133.6	267.2	$151,995.38
TOTAL LABOR BURDEN AND COST (rounded)g					3,075			$152,000
Assumptions:
a We have assumed that the average number of respondents that will be subject to the rule over the three-year period of this ICR will be 167. It is estimated that no additional respondents will become subject to the regulation in the next three years.
b This cost is based on the following hourly labor rates, increased by 60% to account for the benefit packages available to government employees: $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 Clerical (GS-6, Step 3, $17.16 + 60%). These rates are from the Office of Personnel Management (OPM) “2020 General Schedule” which excludes locality rates of pay.
c We have assumed that one respondent will submit a notification of physical or operational change.
d We have assumed that it will take four hours to review the CMS demonstration report.
e We have assumed that it will take eight hours to review the performance test results.
f It will take eight hours to review semiannual report of exceedances.
g Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.