burden calculation tables

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Overview

Table 1
Table 2
O&M

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Sheet 1: Table 1

Table 1: Annual Respondent Burden and Cost – NSPS for Bulk Gasoline Terminals (40 CFR Part 60, Subpart XX) (Renewal)
Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (A x B)	(D) Respondents per year a	(E) Technical person- hours per year (C x D)	(F) Management person hours per year (E x0.05)	(G) Clerical person hours per year (E x 0.1)	(H) Total Cost per year b
1. Applications	N/A									Labor Rates
2. Survey and Studies	N/A									Management	$148.45
3. Reporting requirements										Technical	$121.46
A. Familiarization with Regulatory Requirements c										Clerical	$60.23
Existing sources	2	1	2	214	428	21	43	$57,739.55
New Sources	8	1	8	0	0	0	0	$0
B. Required activities
Initial performance tests d	60	1	60	0	0	0	0	$0
Repeat of performance tests d	60	0.1	6	0	0	0	0	$0
Monitoring of operations and equipment e	See 4E
C. Gather existing information	See 3B and 4E
D. Write Report
Notification of compliance status d, f	2	1	2	0	0	0	0	$0
Notification of actual startup f	2	1	2	0	0	0	0	$0
Notification of construction/reconstruction f	2	1	2	0	0	0	0	$0
Report of performance test results d	See 3B
Operation and maintenance reports	N/A
Annual/Semiannual reports g	N/A
Subtotal for Reporting Requirements					492			$57,740
4. Recordkeeping requirements
A. Familiarization with Regulatory Requirements	See 3A
B. Plan Activities	See 3A
C. Implement Activities	See 3A
D. Develop record system	N/A
E. Time to enter information
Records of startup, shutdown, malfunction h	1.5	50	75	214	16,050	803	1,605	$2,165,233.28
Record of tank identification numbers i	0.1	2,100	210	214	44,940	2,247	4,494	$6,062,653.17
Leak detection records of monthly control equipment inspections j	0.1	12	1.2	214	257	13	26	$34,643.73
F. Time to train personnel	N/A
G. Time for audits	N/A
Subtotal for Recordkeeping Requirements					70,434			$8,262,530
Total Labor Burden and Costs (rounded) k					70,900			$8,320,000		214	responses
Total Capital and O&M Cost (rounded) k								$0		331	hr / response
GRAND TOTAL (rounded) k								$8,320,000
Assumptions:
a We assume that there are an average of 214 existing sources that are subject to the standard over the three-year period of this ICR. We assume that there will be no new or reconstructed or modified sources per year over the three-year period of this ICR.
b This ICR uses the following labor rates for privately-owned sources: $148.45 for managerial, $121.46 for technical, 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 assume that all existing respondents will take 2 hours each year to re-familiarize with the rule. We assume that all new respondents will take 8 hours to familiarize with the rule.
d We have assumed that it will take 60 hours for each new respondent to perform initial performance tests and submit the report. We assume that 10 percent of new sources will need to repeat the test due to failure.
e Monitoring of operations includes: implementation of Standards Operating Procedures (SOP) for operation and maintenance of control equipment; records of tank identification numbers and monthly leak detection inspection of control equipment.
f Per §60.8(g), compliance status is determined by the permitting authority on examination of the performance test results. §60.7(a)(1) requires notification of the date of construction/reconstruction. §60.7(a)(3) requires notification of the date of actual startup.
g NSPS Subpart XX does not require annual or semiannual reporting.
h We assume that it will take 1.5 hours, fifty times per year, for each respondent to maintain SSM records.
i We assume that each respondent will take 0.1 hour or 6 minutes to enter each tank identification number. We assume an average of six tank truck loadings each day for 350 days a year. (6 loadings/day x 350 days/year = 2,100 loadings/year)
j We assume that each respondent will take 6 minutes to record leak detection information twelve times per year.
k 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 Bulk Gasoline Terminals (40 CFR Part 60, Subpart XX) (Renewal)
Activity	(A) EPA person- hours per occurrence	(B) No. of occurrences per plant per year	(C) EPA person- hours per plant per year (AxB)	(D) Plants per year a	(E) Technical person- hours per year (CxD)	(F) Management person-hours per year (Ex0.05)	(G) Clerical person-hours per year (Ex0.1)	(H) Cost, $ b
Initial notifications c	2	1	2	0	0	0	0	$0		Labor Rates
Report of performance test results d	8	1	8	0	0	0	0	$0		Management	$68.37
Semiannual reports e	N/A									Technical	$50.72
TOTAL (rounded) f					0			$0		Clerical	$27.46
Assumptions:
a We assume that there are an average of 214 existing sources that are subject to the standard over the three-year period of this ICR. We assume that there will be no new or reconstructed or modified sources per year over the three-year period of this ICR.
b This ICR uses the following labor rates: $68.37 for managerial, $50.72 for technical, 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 New /modified/reconstructed sources are required to submit notifications of construction/reconstruction, actual startup, and compliance status.
d New sources are required to submit performance test results. We assume 10 percent of new sources will repeat the test due to failure. (10 + 10 x 0.1 = 11)
e The rule does not require periodic reporting.
f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: O&M

Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports				Total Annual Responses
	(A)	(B)	(C)	(D)	(E)		(A)	(B)	(C)	(D)	(E)
Year	Number of New/Reconstructed + Modified Respondents a	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)		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
1	0	214	0	0	214		Initial notifications	0	1	N/A	0
2	0	214	0	0	214		Report of performance test	0	1.1	N/A	0
3	0	214	0	0	214		Periodic reports	0	1	N/A	0
Average	0	214	0	0	214		Records of operations	214	0	214	214
a New respondents include sources with newly constructed, reconstructed and modified affected facilities.										Total	214
Capital/Startup vs. Operation and Maintenance (O&M) Costs
The only type of industry costs associated with the information collection activity in the regulations are labor costs. There are no capital/startup or operation and maintenance costs.