Burden Calculation Tables

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Overview

# Respondents
# Responses
Respondent Burden
Agency Burden
Capital O&M

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Sheet 1: # Respondents

Number of respondents from 1084.15 (Provided for reference purposes)
Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
	(A)	(B)	(C)	(D)	(E)	ERG Notes:
Year	Number of New Respondents	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	Existing # respondents in yr 3 of prev ICR = 5,161.6; This table calculates the revised number of respondents based on the number of respondents anticipated at the end of the current 3 year period
					(E=A+B+C-D)
1	66.4	5,161.6	0	0	5228.0
2	66.4	5,228.0	0	0	5294.4
3	66.4	5,294.4	0	0	5360.8
Average	66.4	5,228.0	0	0	5,294
1 New respondents include sources with constructed, reconstructed, and modified affected facilities.
Number of respondents from 1084.14 (Provided for reference purposes)
Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
	(A)	(B)	(C)	(D)	(E)	ERG Notes:
Year	Number of New Respondents	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	Existing # respondents in yr 3 of prev ICR = 4,962.4; This table calculates the revised number of respondents based on the number of respondents anticipated at the end of the current 3 year period
					(E=A+B+C-D)
1	66.4	4,962.4	0	0	5028.8
2	66.4	5,028.8	0	0	5095.2
3	66.4	5,095.2	0	0	5161.6
Average	66.4	5,028.8	0	0	5,095
1 New respondents include sources with constructed, reconstructed, and modified affected facilities.
Number of respondents from 1084.13 (Provided for reference purposes)
Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
	(A)	(B)	(C)	(D)	(E)
Year	Number of New Respondents	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	66.4	4,763.2	0	0	4,829.6
2	66.4	4,829.6	0	0	4,896
3	66.4	4,896	0	0	4,962.4
Average	66.4	4,829.6	0	0	4,896
1 New respondents include sources with constructed, reconstructed, and modified affected facilities.
Number of respondents from 1084.12 (Provided for reference purposes)
Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
	(A)	(B)	(C)	(D)	(E)
Year	Number of New Respondents	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	66.4	4,564	0	0	4,630.4
2	66.4	4,630.4	0	0	4,696.8
3	66.4	4,696.8	0	0	4,763.2
Average	66.4	4,630	0	0	4,697

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Sheet 2: # Responses

Total Annual Responses
(A) Information Collection Activity	(B) Number of Respondents	(C) Number of Responses	(D) Number of Existing Respondents That Keep Records But Do Not Submit Reports	(E) Total Annual Responses E=(BxC)+D
Notification of actual startup	66.4	1	0	66.4
Notification of initial performance test	66.4	1	0	66.4
Notification of physical/operational change	66.4	1	0	66.4
Report of initial performance test (new sources)	66.4	1	0	66.4
Report of repeat initial performance test (new sources)	16.6	1	0	16.6
Report of five-year performance test (existing sources)	60.9	1	0	60.9
Records of startups, shutdowns, and malfunctions	0	0	5,294	5,294
			Total	5,637.5
			hrs/response:	4

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Sheet 3: Respondent Burden

Table 1: Annual Respondent Burden and Cost – NSPS for Nonmetallic Mineral Processing (40 CFR Part 60, Subpart OOO) (Renewal)										Source Type	No.
										Existing	5,294
				Labor Rates:	$122.66	$149.84	$60.88			New (crushed/broken stone and sand/gravel sectors)	60.9
Burden item	A	B	C	D	E	F	G	H		New (other sectors)	5.5
	Person-hours per occurrence	Annual occurrences per respondent	Person-hours per respondent per year (AxB)	Respondents per year a	Technical hours per year (CxD)	Management hours per year (Ex0.05)	Clerical hours per year (Ex0.10)	Annual cost ($) b
1. Applications	N/A
2. Surveys and studies	N/A
3. Acquisition, installation, and utilization of technology and systems	N/A										Respondant Rates (Source: United States Department of Labor, Bureau of Labor Statistics, June 2017, “Table 2. Civilian Workers, by occupational and industry group.”)
4. Reporting requirements											Labor Type	Total Compensation ($/hr)	Loaded Rate (Rate + 110%rate)
A. Familiarization with regulatory requirements	1	1	1	5,294.4	5,294.4	264.72	529.44	$721,312.50			Mgmt.	$71.35	$149.84
B. Required activities											Tech.	$58.41	$122.66
Monitoring: wet suppression c	0.17	12	2.04	60.9	124.24	6.21	12.42	$16,926.00			Cler.	$28.99	$60.88
Monitoring: M22 readings d	1	4	4	5.5	22	1.1	2.2	$2,997.29
C. Create information	See 4B
D. Gather existing information	See 4E
E. Write reports
Notification of actual startup	2	1	2	66.4	132.8	6.64	13.28	$18,092.76
Notification of initial performance test	2	1	2	66.4	132.8	6.64	13.28	$18,092.76
Report of performance test	See 5B
Notification of physical/operational change	2	1	2	66.4	132.8	6.64	13.28	$18,092.76
Reporting Subtotal					6,715			$795,514
5. Recordkeeping
A. Familiarization with regulatory requirements	See 4A
B. Plan activities
Initial performance test (new sources) e	30	1	30	66.4	1,992	99.6	199.2	$271,391.37
Repeat initial performance test (new sources) e, f	30	1	30	16.6	498	24.9	49.8	$67,847.84
Five-year performance test (existing sources) e, g	30	1	30	60.9	1,827	91.35	182.7	$248,911.67
C. Implement activities	See 4B
D. Record data
Monitoring: wet suppression	0.1	1	0.1	60.9	6.09	0.3	0.61	$829.09
Monitoring: M22 readings	0.2	1	0.2	5.5	1.1	0.06	0.11	$150.61
E. Time to transmit or disclose information
Records of startups, shutdowns, and malfunctions	1.5	1	1.5	5,294	7,942	397.1	794.2	$1,081,968.75
F. Time to train personnel	N/A
G. Time for audits	N/A
Recordkeeping Subtotal					14,105			$1,671,099
TOTAL LABOR BURDEN AND COSTS (rounded) h					20,800			$2,470,000
TOTAL CAPITAL AND O&M COST (rounded) h								$228,000
GRAND TOTAL (rounded) h								$2,700,000
N/A - Not Applicable
Assumptions:
a EPA estimates an average of 5,294 existing sources will be subject to the standard and 66.4 new sources per year will become subject over the next three years. These estimates are based on model plant parameters used in development of the original promulgated NSPS and 2005/2006 USGS production data. Of the 66.4 new respondents per year, EPA estimates 60.9 will be in the crushed/broken stone and sand/gravel industrial sectors and 5.5 will be in other industrial sectors.
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 Monitoring for wet suppression involves checking that water is actually flowing. EPA estimates it will occur on a monthly basis and take 10 minutes per check. Wet suppression is expected to be used in the crushed/broken stone and sand/gravel industrial sectors.
d EPA estimates it will take each respondent one hour four times per year to complete Method 22 readings. All other industry sectors except for crushed/broken stone and sand/gravel are expected to use baghouses and will employ baghouse Method 22 readings to comply with the periodic monitoring requirements.
e Includes 8 hours to develop and review performance test report and 22 hours to plan for performance testing. The time required to conduct Method 5 and Method 9 performance tests is included under capital costs because a contractor is typically hired to perform these tests.
f EPA assumes 25% of initial performance tests will be repeated due to failure (66.4 x 0.25 = 16.6).
g Existing sources in the crushed/broken stone and sand/gravel industrial sectors, built in 2008 or later, must repeat performance testing every five years. Over the next three years (2022 to 2024), an average of 60.9 existing sources per year will repeat performance testing. These existing sources were the new sources that conducted initial performance testing in 2017, 2018, and 2019.
h Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 4: Agency Burden

Table 2: Average Annual EPA Burden and Cost – NSPS for Nonmetallic Mineral Processing (40 CFR Part 60, Subpart OOO) (Renewal)
				Labor Rates:	$51.23	$69.04	$27.73
Burden item	A	B	C	D	E	F	G	H
	EPA person-hours per occurrence	Annual occurrences per respondent	EPA person-hours per respondent per year (AxB)	Respondents per year a	Technical hours per year (CxD)	Management hours per year (Ex0.05)	Clerical hours per year (Ex0.10)	Annual cost ($) b				Agency Rates Source: Office of Personnel Management (OPM), 2017 General Schedule
Initial performance test (new sources)	24	1	24	66.4	1,593.6	79.68	159.36	$91,563.16					Hourly Mean Wage	With Fringe & Overhead
Repeat initial performance test (new sources) c	24	1	24	16.6	398.4	19.92	39.84	$22,890.79				(GS- 12, step 1) - Tech.	32.02	$51.23
Five-year performance test (existing sources)	24	1	24	60.9	1,461.60	73.08	146.16	$83,978.86				(GS- 13, step 5) - Mgmt.	43.15	$69.04
Report review (new sources)												(GS-6, step 3) - Cler.	17.33	$27.73
Notification of actual startup	0.5	1	1	66.4	33.2	1.66	3.32	$1,907.57
Notification of initial performance test	0.5	1	1	66.4	33.2	1.66	3.32	$1,907.57
Report of initial performance test d	8	1	8	83	664	33.20	66.40	$38,151.32
Notification of physical/operational change	0.5	1	1	66.4	33.2	1.66	3.32	$1,907.57
Report review (existing sources)
Report of five-year performance test	8	1	8	60.9	487.2	24.36	48.72	$27,992.95
TOTAL (rounded)e					4,850			$270,000
Assumptions:
a EPA estimates an average of 5,294 existing sources will be subject to the standard and 66.4 new sources per year will become subject over the next three years. These estimates are based on model plant parameters used in development of the original promulgated NSPS and 2005/2006 USGS production data. Of the 66.4 new respondents per year, EPA estimates 60.9 will be in the crushed/broken stone and sand/gravel industrial sectors and 5.5 will be in other industrial sectors.
b This ICR uses the following labor rates: $51.23 (technical), $69.04 (managerial), and $27.73 (clerical). 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 EPA assumes 25% of initial performance tests will be repeated due to failure (66.4 x 0.25 = 16.6).
d Includes EPA review of initial and repeat performance tests conducted by new sources (66.4 + 16.6 = 83).
e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 5: Capital O&M

Costs from 1084.13 and 14 (Provided for reference purposes)
Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A)	(B)	(C)	(D)	(E)	(F)	(G)
Requirement	Capital/Startup Cost for One Respondent	Number of New Respondents a	Total Capital/Startup Cost, (B X C x CRF) b, f	Annual O&M Costs for One Respondent	Number of Respondents with O&M	Total O&M, (E X F)
Method 9 performance tests (new sources) c	$4,767	60.9	$70,807	$0	0	$0
Method 9 performance tests (existing sources) c, d	$4,767	60.9	$70,807	$0	0	$0
Method 5 performance tests (new sources) e	$63,000	5.5	$84,511	$0	0	$0
File cabinets	$235	66.4	$1,713	N/A	N/A	N/A
Total f			$228,000			$0
N/A - Not Applicable
a Of the 66.4 new respondents per year, EPA estimates 60.9 will be in the crushed/broken stone and sand/gravel industrial sectors and 5.5 will be in other industrial sectors.
b These are annualized costs for all new respondents. The capital cost associated with testing was annualized assuming a 7% interest rate and 5-year life (i.e., capital recovery factor (CRF) of 0.2439). The annualized capital cost for file cabinets was calculated using a 7% interest rate and a 15-year life (i.e., CRF of 0.1098).
c EPA estimates a testing cost of $216.67 per 30-minute Method 9 test. EPA assumes each plant in the crushed/broken stone and sand/gravel industrial sectors has 22 emissions points requiring Method 9 testing; therefore, the capital/startup cost per respondent is $4,767 (rounded) ($216.67x22 = 4,766.74).
d Existing sources in the crushed/broken stone and sand/gravel industrial sectors, built in 2008 or later, must repeat performance testing every five years. Over the next three years (2022 to 2024), an average of 60.9 existing sources per year will repeat performance testing. These existing sources were the new sources that conducted initial performance testing in 2017, 2018, and 2019.
e EPA estimates a testing cost of $7,000 per Method 5 test. EPA assumes each plant in other industrial sectors subject to the rule has 9 emission points requiring Method 5 testing; therefore, the capital/startup cost per respondent is $63,000 ($7,000x9 = $63,000).
f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
Costs from 1084.12 (Provided for reference purposes)
Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A)	(B)	(C)	(D)	(E)	(F)	(G)
Requirement	Capital/Startup Cost For One Respondent	Number of New Respondents b	Total Capital/Startup Cost, (B X C)c	Annual O&M Costs for One Respondent	Number of Respondents with O&M	Total O&M Costs
Performance Tests a	N/A	66.4	$152,868	0	0	0
File Cabinets	N/A	66.4	$1,709	N/A	N/A	N/A
Total			$154,577	0	0	0
a The total costs for performance testing were calculated for each industry sector covered by subpart OOO. A testing cost of $7,000 for Method 5 tests and $216.67 for a 30-minute Method 9 tests was used. It was assumed there are 22 emission points for each plant in the crushed/broken stone and sand/gravel sectors and 9 emission points for each plant in other sectors.
b Growth in each of the NMPP sectors was estimated using model plants and recent (e.g., 2005/2006) production data available from the U.S. Geological Survey (USGS) and model plant parameters used in development of the original promulgated NSPS. It is estimated that, of the 66.4 new respondents per year, 60.9 will be in the crushed/broken stone and sand/gravel sectors and 5.5 will be in other sectors.
c These are annualized costs for all new respondents. The capital cost associated with testing was annualized assuming a 7 percent interest rate and 5-year life (i.e., capital recovery factor [CRF] of 0.2439). The annualized capital cost for file cabinets was calculated using a 7 percent interest rate and a 15-year life (i.e., CRF of 0.1098). The total cost for performance testing is $626,767 per year, and the total capital cost for filing cabinets was estimated at $15,604. Over the 3-year period, performance test costs are $1.0 million and $872,000 for Method 5 and Method 9 respectively.
	Number of sources conducting repeat performace testing
	ICR	Calendar Year	ICR Year	New Sources	Repeating Performance Testing											NOTES
					2010 Sources	2011 Sources	2012 Sources	2013 Sources	2014 Sources	2015 Sources	2016 Sources	2017 Sources	2018 Sources	2019 Sources	Total Sources
	1084.10	2010	Yr 1	60.9	Initial Test	N/A	N/A	N/A							N/A
	1084.10	2011	Yr 2	60.9	0	Initial Test	N/A	N/A							0
	1084.10	2012	Yr 3	60.9	0	0	Initial Test	N/A							0
	1084.12	2013	Yr 1	60.9	0	0	0	Initial Test							0
	1084.12	2014	Yr 2	60.9	0	0	0	0	Initial Test						0
	1084.12	2015	Yr 3	60.9	60.9	0	0	0		Initial Test					60.9	1084.12 ICR applied 3-yr average of 20.3 sources/yr for repeat testing
	1084.13	2016	Yr 1	60.9		60.9	0	0			Initial Test				60.9
	1084.13	2017	Yr 2	60.9			60.9	0				Initial Test			60.9
	1084.13	2018	Yr 3	60.9				60.9					Initial Test		60.9	3-yr average for repeat testing: 60.9
	1084.14	2019	Yr 1	60.9					60.9					Initial Test	60.9
	1084.14	2020	Yr 2	60.9						60.9					60.9
	1084.14	2021	Yr 3	60.9							60.9				60.9	3-yr average for repeat testing: 60.9
	1084.15	2022	Yr 1	60.9								60.9			60.9
	1084.15	2023	Yr 2	60.9									60.9		60.9
	1084.15	2024	Yr 3	60.9										60.9	60.9	3-yr average for repeat testing: 60.9