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 Phosphate Fertilizer Industry (40 CFR Part 60, Subparts T, U, V, W and X) (Renewal)
Burden Item	A	B	C	D	E	F	G	H
	Person Hours Per Occurrence	Number of Occurrences Per Respondent Per Year	Person Hours Per Respondent Per Year (C=AxB)	Respondents Per Year a	Technical Person-Hours Per Year (E=CxD)	Management Person Hours Per Year (E x 0.05)	Clerical Person Hours Per Year (E x 0.10)	Total Costs Per Year ($) b
1. Applications	N/A									Labor Rates
2. Survey and Studies	N/A									Management	$153.55
3. Reporting Requirements										Technical	$122.20
A. Familiarization with rule requirements	1	1	1	13	13	0.65	1.3	$1,768.37		Clerical	$61.51
B. Required activities
New Sources
Initial Performance Test
AOCA Method 9 tests c	29.7	1	29.7	0	0	0	0	$0
Reference Method 13A or 13B tests d	4	1	4	0	0	0	0	$0
Repeat performance test e	4	0.2	0.8	0	0	0	0	$0
C. Create Information	See 3B
D. Gather existing information	See 3E
E. Write Report
New Sources
Notification of construction/reconstruction	2	1	2	0	0	0	0	$0
Notification of actual startup	2	1	2	0	0	0	0	$0
Notification of initial performance test	2	1	2	0	0	0	0	$0
Notification of CMS demonstration	2	1	2	0	0	0	0	$0
Report of initial performance test	See 3B
Site-specific methodology plan f	2	1	2	0	0	0	0	$0
Existing Sources
Notification of operational change g	2	1	2	2	4	0.2	0.4	$544.11
Semiannual report of exceedances h	2	2	4	13	52	2.6	5.2	$7,073.48
Subtotal Reporting Requirements					79			$9,386
4. Recordkeeping Requirements
A. Read and understand rule requirements	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 operation parameters and emissions i	0.25	350	87.5	13	1,138	57	114	$154,732.42
Subtotal Recordkeeping Requirements					1,308			$154,732
Total Labor Burden and Cost (rounded)j					1,390			$164,000		50	hrs/response
Total Capital and O&M Costs (rounded)j								$320,000
GRAND TOTAL (rounded)j								$484,000
Assumptions:
a We have assumed that an average of 13 respondents that will be subject to the rule, and there will be no additional new sources that will become subject to the rule over the three-year period of this ICR.
b This ICR uses the following labor rates: Managerial $153.55 ($73.12+ 110%); Technical $122.20 ($58.19 + 110%); and Clerical $61.51 ($29.29 + 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2021, “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. This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours.
c As specified in the general provisions, each performance test shall consist of three separate runs using the applicable test method. Sources are required to use the spectrophotometric molybdovanadophosphate method (AOAC) Method 9 published in the 11 Edition of the Official Methods of Analysis of the Association of Official Analytical Chemists dated 1970, to determine the P2O5 feed rate. No sources are anticipated to conduct an initial performance test because there are no new sources anticipated over the period of this ICR.
d As specified in the general provisions, each performance test shall consist of three separate runs using the applicable test method. Each run shall be conducted for the time and under the conditions specific in the applicable rule. For these rules, the total fluoride concentration and volumetric flow rate of the effluent gas shall be determined by Method 13 which requires a sampling time and a sample volume for each run of at least 60 minutes and 0.85 dscm (30 dscf). No sources are anticipated to conduct an initial performance test because there are no new sources anticipated over the period of this ICR.
e We assume that 20 percent of initial performance tests must be repeated due to failure.
f Only sources that have a granular triple superphosphate storage facility are required to submit this initial plan. No sources are anticipated to submit this plan because there are no new sources anticipated over the period of this ICR.
g We assume that 15 percent of the sources will submit notifications of operational changes.
h We assume that each source will submit a semiannual report due to excess emission and monitoring systems performance over the three-year period.
i Sources are required to maintain a daily record of operating parameters (e.g., determine equivalent P2O5 content and total pressure drop across the scrubbing system). We assume that the operation is 350 days per year as specified in the NSPS review document.
j 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 Phosphate Fertilizer Industry (40 CFR Part 60, Subparts T, U, V, W and X) (Renewal)
Burden Item	A	B	C	D	E	F	G	H
	EPA Hours per Occurrence	Number of Occurrences Per Year	EPA Person Hours Per Year (A x B)	Plants Per Year a	Technical Hours Per Year (C x D)	Management Hours Per Year (E x 0.05)	Clerical Hours Per Year (E x 0.10)	Total Cost Per Year ($) b
Report Review										Labor Rates
New Plants										Management	$69.04
Notification of construction/reconstruction	2	1	2	0	0	0	0	$0		Technical	$51.23
Notification of initial startup	0.5	1	0.5	0	0	0	0	$0		Clerical	$27.73
Notification of actual startup	0.5	1	0.5	0	0	0	0	$0
Notification of initial test	0.5	1.2	0.6	0	0	0	0	$0
Review test results	8	1.2	9.6	0	0	0	0	$0
Notification of CMS demonstration	0.5	1	0.5	0	0	0	0	$0
Existing Plants
Review notification of operational change c	0.5	1	2	2	4	0.2	0.4	$229.82
Semiannual report d	1	2	2	13	26	1.3	2.6	$1,493.83
TOTAL COST (rounded) e					35			$1,720
Assumptions:
a We have assumed that an average of 13 respondents that will be subject to the rule, and there will be no additional new sources that will become subject to the rule over the three-year period of this ICR.
b This cost is based on the average hourly labor rate as follows: Managerial $69.04 (GS-13, Step 5, $43.15 + 60%); Technical $51.23 (GS-12, Step 1, $32.02 + 60%); and Clerical $27.73 (GS-6, Step 3, $17.33 + 60%). This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. These rates are from the Office of Personnel Management (OPM), 2021 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 We have assumed that it will take 0.5 hours twice per year to review the notification of operational change.
d We have assumed that it will take one hour twice per year to review the semiannual reports.
e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: O&M

Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A)	(B)	(C)	(D)	(E)	(F)	(G)
Continuous Monitoring Device	Capital/Startup Cost for One Respondent	Number of New Respondents	Total Capital/Startup Cost, (B x C)	Annual O&M Costs for One Respondent	Number of Respondents with O&M	Total O&M, (E x F)
Pressure drop monitor	$27,720	0	$0	$24,630	13	$320,190
TOTAL a						$320,000
a Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
	(A)	(B)	(C)	(D)	(E)
Year	Number of New 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)
1	0	13	0	0	13
2	0	13	0	0	13
3	0	13	0	0	13
Average	0	13	0	0	13
a New respondents include sources with constructed, reconstructed and modified affected facilities.
Total Annual Responses
(A)	(B)	(C)	(D)	(E)
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
Notification of Operational Change	2	1	N/A	2
Semiannual Report	13	2	N/A	26
			Total	28