Burden Calculation Tables

---

Overview

Industry
Agency
Capital and O&M

---

Sheet 1: Industry

Burden item	(A) Person-hours per occurrence	(B) No. of occurrence per respondent per year	(C) Person-hours per respondent per year (C = A x B)	(D) Respondents per yeara	(E) Technical person-hours per year (E = C x D)	(F) Management person-hours per year (E x 0.05)	(G) Clerical person hours per year (E x 0.1)	(H) Cost b $		Respondent Rates (Source: United States Department of Labor, Bureau of Labor Statistics, September 2020, “Table 2. Civilian Workers, by occupational and industry group.”)
1. Applications	N/A									Labor Type	Total Compensation ($/hr)	Loaded Rate (Rate + 110%rate)
2. Survey and Studies	N/A									Mgmt.	$71.35	$149.84
3. Reporting Requirements										Tech.	$58.41	$122.66
A. Familiarization with regulatory requirements	1	1	1	46	46	2.3	4.6	$6,267.07		Cler.	$28.99	$60.88
B. Required activities
i. Initial Performance Test	60	1	60	0	0	0	0	$0
ii. Repeat Performance Test c	60	0.2	12	0	0	0	0	$0
C. Gather Existing Information	3B
D. Write report
i. Notification of construction/ reconstruction	2	1	2	0	0	0	0	$0
ii. Notification of initial performance test	2	1.2	2.4	0	0	0	0	$0
iii. Notification of actual startup	2	1	2	0	0	0	0	$0
iv. Report of performance test	3B
v. Semiannual report d	8	2	16	46	736	36.8	73.6	$100,273.12
vi. Excess emissions report d	5	0.5	2.5	46	115	5.75	11.5	$15,667.67
Subtotal for Reporting Requirements					1,032			$122,208
4. Recordkeeping Requirements
A. Familiarization with regulatory requirements	3A
B. Plan activities	3B
C. Implement activities (Monthly Performance Test)	1	12	12	46	552	27.6	55.2	$75,204.84
D. Develop record system	N/A
i. Records of operating parameter e	0.25	250	62.5	46	2875	143.75	287.5	$391,691.87
Subtotal for Recordkeeping Requirements					3,941			$466,897
TOTAL LABOR BURDEN AND COSTS (rounded): f					4,970			$589,000
TOTAL CAPITAL AND O&M COST (rounded): f								$97,000		43	hr/resp
GRAND TOTAL (rounded): f								$686,000
Assumptions:
a Assumes an average of 46 affected facilities, with no new plants coming online.
b This ICR uses the following labor rates: $122.66 (technical), $149.84 (managerial), and $60.88 (clerical). 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.” They have been increased by 110 percent to account for the benefit packages available to those employed by private industry.
c Assumed 20% rate of failed performance tests.
d Each plant files an excess emission report every other year and a semiannual report twice a year.
e Assume operation 250 days per year as specified in the NSPS review document.
f Totals have been rounded to 3 significant values. Figures may not add exactly due to rounding.

---

Sheet 2: Agency

Activity	(A) EPA person-hours per occurrence	(B) No. of occurrences per plant per year	(C) EPA person-hours per plant per year (C = A x B)	(D) Plants per year a	(E) Technical person-hours per year (E = C x D)	(F) Management person-hours per year (E x 0.05)	(G) Clerical person-hours per year (E x 0.1)	(H) Cost b $		Agency Rates Source: Office of Personnel Management (OPM), 2021 General Schedule
1. Initial Performance Test	23	1	23	0	0	0	0	$0			Hourly Mean Wage	With Fringe & Overhead
2. Repeat Performance Test c	23	1	23	0	0	0	0	$0		(GS- 12, step 1) - Tech.	32.02	$51.23
3. Report Review										(GS- 13, step 5) - Mgmt.	43.15	$69.04
A. New Plants										(GS-6, step 3) - Cler.	17.33	$27.73
i. Noification of Construction	2	1	2	0	0	0	0	$0
ii. Notification of Initial Startup	0.5	1	0.5	0	0	0	0	$0
iii. Notification of Actual Startup	0.5	1	0.5	0	0	0	0	$0
iv. Notification of Initial Test	0.5	1.2	0.6	0	0	0	0	$0
v. Review Test Results	8	1.2	9.6	0	0	0	0	$0
B. Existing Plants
i. Semiannual Reports	2	2	4	46	184	9.2	18.4	$10,572.05
ii. Excess Emissions Reports	2	0.5	1	46	46	2.3	4.6	$2,643.01
TOTAL (rounded): d					265			$13,200
Assumptions:
a Assumes an average of 46 affected facilities, with no new plants coming online.
b This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: $69.04 Managerial rate (GS-13, Step 5, $43.15 x 1.6), $51.23 Technical rate (GS-12, Step 1, $32.02 x 1.6), and $27.73 Clerical rate (GS-6, Step 3, $17.33 x 1.6). These rates are from the Office of Personnel Management (OPM) 2021 General Schedule, which excludes locality rates of pay.
c Assumed 20% rate of failed performance tests.
d Totals have been rounded to 3 significant values. Figures may not add exactly due to rounding.

---

Sheet 3: Capital and O&M

6(b)(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs
Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A) Continuous Monitoring Device	(B) Capital/Startup Cost for One Respondent	(C) Number of New Respondents	(D) Total Capital/ Startup Cost, (B X C)	(E) Annual O&M Costs for One Respondent	(F) Number of Respondents with O&M	(G) Total O&M, (E X F)
Temperature	$8,000	0	$0	$2,100	46	$96,600