Burden Calculations

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Overview

Industry
Agency

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Sheet 1: Industry

Table 1: Annual Respondent Burden and Cost – NESHAP for Natural Gas Transmission and Storage (40 CFR Part 63, Subpart HHH) (Renewal)
					122.66	149.84	60.88
Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical person- hours per year (E=CxD)	(F) Management person hours per year (Ex0.05)	(G) Clerical person hours per year (Ex0.1)	(H) Total Cost per year b
1. Applications	N/A
2. Survey and Studies	N/A
3. Reporting requirements
A. Familiarize with regulatory requirementsc	2	1	2	73	146	7.3	14.6	$19,891.04
B. Required activities	N/A
C. Create information	N/A
D. Gather existing information	4	1	4	73	292	14.6	29.2	$39,782.08
E. Write Report																		# of responses
i. Notification of construction/ reconstructiond	2	1	2	6	12	0.6	1.2	$1,634.88	<--Note to EPA: the existing ICR does not include burden for the one-time notification of a change in major source status. The MM2A rule says "This action does not impose any new information-collection burden under the PRA. Specifically, this rule requires the electronic reporting of the one-time notification already required in 40 CFR 63.9(j) in the case where the facility is notifying of a change in major source status." Most ICRs do not include burden for these infrequent submittals, but advise if a line should be added to account for this notification.									6
ii. Notification of actual startupd	2	1	2	6	12	0.6	1.2	$1,634.88										6
iii. Notification of date of CMS performance evaluationd	2	1	2	6	12	0.6	1.2	$1,634.88										6
iv. Notification of planned date of performance testd	2	1	2	6	12	0.6	1.2	$1,634.88										6
v. Notification of compliance status reportd	4	1	4	6	24	1.2	2.4	$3,269.76										6
vi. Semiannual Periodic Report	4	2	8	73	584	29.2	58.4	$79,564.16										146
Subtotal for Reporting Requirements					1258			$149,046.56										176	Total Response
4. Recordkeeping requirements																		21	Hours/response
A. Familiarize with regulatory requirements	See 3A
B. Plan activitiesd	16	1	16	6	96	4.8	9.6	$13,079.04
C. Implement activities	N/A
D. Develop record system
i. Control equipmentd	4	1	4	6	24	1.2	2.4	$3,269.76
E. Time to enter information
i. Control device designd	4	1	4	6	24	1.2	2.4	$3,269.76
ii. Control equipment testingd	1	1	1	6	6	0.3	0.6	$817.44
iii. Control equipment inspection	8	2	16	73	1168	58.4	116.8	$159,128.32
iv. Control equipment monitoring	1	2	2	73	146	7.3	14.6	$19,891.04
v. Control device CMS	1	6	6	73	438	21.9	43.8	$59,673.12
F. Time to train personnel	4	1	4	73	292	14.6	29.2	$39,782.08
G. Perform Audits	N/A
H. Retain records of actual throughput (facilities exempt under 63.1270(f)e	N/A
Subtotal for Recordkeeping Requirements					2,523			$298,910.56
TOTAL LABOR BURDEN AND COST (rounded)f					3,780			$448,000
TOTAL CAPITAL AND O&M COST (rounded)f								$0
GRAND TOTAL (rounded)f								$448,000
Assumptions:
a We have assumed that there are approximately 67 respondents subject to the rule, on average over the three year period. It is estimated that 6 additional new or reconstructed sources becoming subject to the rule annually over the next three years, for a total of 73 respondents.
b This ICR uses the following labor rates: $149.84 per hour for Executive, Administrative, and Managerial labor; $122.66 per hour for Technical labor, and $60.88 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 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 It is estimated that each source will familiarize themselves with the rule requirements each year.
d One-time requirement for the 6 new or reconstructed sources. Performance test reports are submitted with the Notification of Compliance Status and must be developed using EPA’s Electronic Reporting Tool (ERT) and submitted through the EPA’s Compliance and Emissions Data Reporting Interface (CEDRI).
e Respondents are expected to maintain records of actual annual throughput as a standard business practice; therefore, there is no additional burden associated with these records under this rule.
f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 2: Agency

Table 2: Average Annual EPA Burden and Cost – NESHAP for Natural Gas Transmission and Storage (40 CFR Part 63, Subpart HHH) (Renewal)
					51.23	69.04	27.73
Activity	(A) EPA person- hours per occurrence	(B) No. of occurrences per plant per year	(C) EPA person- hours per plant per year (C=AxB)	(D) Plants per year a	(E) Technical person- hours per year (E=CxD)	(F) Management person-hours per year (Ex0.05)	(G) Clerical person-hours per year (Ex0.1)	(H) Cost, $ b
Review reports
a. Initial notification	2	1	2	6	12	0.6	1.2	$689.46
b. Preconstruction review application	4	1	4	6	24	1.2	2.4	$1,378.92
c. Performance test notification	2	1	2	6	12	0.6	1.2	$689.46
d. Compliance status notification	4	1	4	6	24	1.2	2.4	$1,378.92
e. Semiannual periodic reports	2	2	4	73	292	14.6	29.2	$16,776.86
TOTAL ANNUAL BURDEN AND COSTc					419			$20,900
Assumptions:
a We have assumed that there are approximately 67 respondents subject to the rule, on average over the three year period. It is estimated that 6 additional new or reconstructed sources becoming subject to the rule annually over the next three years, for a total of 73 respondents.
b This cost is based on the following hourly labor rates times a 1.6 benefits multiplication factor to account for government overhead expenses: $69.04 for Managerial, $51.23 for Technical, and $27.73 for Clerical. These rates are from the Office of Personnel Management (OPM) “2021 General Schedule” which excludes locality rates of pay.
c Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.