Burden Calculation Tables

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Overview

Summary
Industry
Agency
Capital O&M
Responses
Respondents

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Sheet 1: Summary

ICR Summary Information
Hours per Response	54
Number of Respondents	660
Total Estimated Burden Hours	71,500
Total Estimated Costs	$18,500,000
Annualized Capital O&M	$9,900,000
Total Annual Responses	1,320

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Sheet 2: Industry

Table 1: Annual Respondent Burden and Cost –NSPS for Fossil Fuel Fired Steam Generating Units (40 CFR Part 60, SubpartD) (Renewal)

Burden Item

(A) Person hours per occurrence

(B) Number 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 (F=Ex0.05)

(G) Clerical person hours per year (G=Ex0.1)

(H) Cost, ($) b

1. Applications

N/A

Labor Rates:

2. Survey and Studies

N/A

Management

157.61

These rates were updated 4/5/22 to match the United States Department of Labor, Bureau of Labor Statistics, September 2021, “Table 2. Civilian Workers, by occupational and industry group

3. Reporting Requirements

Technical

123.94

A. Familiarization with Regulatory Requirements c

1

1

1

660

660

33

66

$91,127.85

Clerical

62.52

B. Initial performance test d

N/A

C. Create information d

N/A

D. Gather Existing Information

See 3E

E. Write report

Notification of construction/reconstruction d

N/A

Notification of anticipated/actual startup d

N/A

Notify of emission test d

N/A

Report of initial emission test d

N/A

Excess emissions report e

1

2

2

660

1,320

66

132

$182,255.70

Subtotal Reporting Requirements

2,277

$273,384

4. Recordkeeping Requirements

A. Familiarization with Regulatory Requirements c

See 3A

B. Plan activities

See 4C

C. Implement activities

See 3B

D. Develop record system

N/A

E. Time to check computer system and calibrate continuous monitors f

0.25

365

91.25

660

60,225

3,011.25

6,022.5

$8,315,416.31

F. Time to Train Personnel

N/A

G. Time For Audits

N/A

Subtotal Recordkeeping Requirements

69,259

$8,315,416

Total Labor Burden and Costs (rounded) g

71,500

$8,590,000

Total Capital and O&M Cost (rounded) g

$9,900,000

Grand Total (rounded) g

$18,500,000

54

Assumptions:

hr/response

a We have assumed that the average number of respondents that will be subject to the rule will be 660. 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: $157.61 per hour for Executive, Administrative, and Managerial labor; $123.94 per hour for Technical labor, and $62.52 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 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% to account for the benefit packages available to those employed by private industry.

c We assume that all respondents will have to familiarize with the regulatory requirements and it will take 1 hour per respondent.

d There have been no new subpart D units since 1986, and new units are not expected over the three-year period of this ICR; therefore, this burden item is not applicable.

e We assume that each source will submit a semiannual report due to excess emission and monitoring systems performance over the three-year period.

f We assume that respondents conduct this activity on a daily basis, and that plant operations occur 365 days per year.

g Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding

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Sheet 3: Agency

Table 2: Average Annual EPA Burden and Cost – NSPS for Fossil Fuel Fired Steam Generating Units (40 CFR Part 60, Subpart D) (Renewal)

Burden Item

(A) EPA Hours per Occurrence

(B) Number of occurrences per plant per year

(C) EPA Person hour per year (C=AxB)

(D) Plants per year a

(E) Technical hours per year (E=CxD)

(F) Management hours per year (F=Ex0.05)

(G) Clerical hours per year (G=Ex0.10)

(H) Cost, ($) b

Report Review

Labor Rates:

Notification of construction

N/A

Management

70.56

These rates were updated 4/5/2022 to match the rates from the Office of Personnel Management (OPM), 2022 General Schedule.

Notification of anticipated startup

N/A

Technical

52.37

Notification of actual startup

N/A

Clerical

28.34

Notification of Initial Test

Sulfur dioxide c

N/A

Particulate matter c

N/A

Nitrogen oxides c

N/A

Review Initial Test Results

Sulfur dioxide c

N/A

Particulate matter c

N/A

Nitrogen oxides c

N/A

Review Notification of CMS Demonstration

Sulfur dioxide c

N/A

Particulate matter c

N/A

Nitrogen oxides c

N/A

Review CMS Performance Demonstration

Sulfur dioxide c

N/A

Particulate matter c

N/A

Nitrogen oxides

N/A

Review excess emission reports d

1

2

2

460

920

46

92

$54,033.44

Review sulfur dioxide compliance reports d, e

Coal-Fired units

2

2

4

133

532

26.6

53.2

$31,245.42

Oil-Fired units

2

2

4

67

268

13.4

26.8

$15,740.18

Travel expenses

N/A

Total Annual Burden and Cost (rounded) f

1,980

$101,000

Assumptions:

a We have assumed that the average number of respondents that will be subject to the rule will be 660. 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 following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: Managerial rate of $70.56 (GS-13, Step 5, $41.07 + 60%), Technical rate of $52.37 (GS-12, Step 1, $30.47 + 60%), and Clerical rate of $28.34 (GS-6, Step 3, $16.49 + 60%). These rates are from the Office of Personnel Management (OPM) “2020 General Schedule” which excludes locality rates of pay.

c There have been no new subpart D units since 1986, and new units are not expected over the three-year period of this ICR; therefore, this burden item is not applicable.

d We assume that approximately 70 percent of the sources monitor via CEM and that approximately 30 percent use fuel sampling and analysis.

e Units using fuel sampling and analysis submit sulfur dioxide compliance reports instead of excess emission reports, which are based on CEM data. The figures used in this category are based on research performed during regulation revision.

f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding

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Sheet 4: Capital 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)
SO2, PM, and NOx	$200,000	0	$0	$15,000	660	$9,900,000
Totals (rounded)			$0			$9,900,000
Note: Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 5: Responses

Total Annual Responses
(A)	(B)	(C)	(D)	(E)
Information Collection Activity	Number of Respondents a	Number of Responses	Number of Existing Respondents That Keep Records But Do Not Submit Reports	Total Annual Responses E=(BxC)+D
Semiannual report	660	2	0	1,320
			Total	1,320
a We assume that each source will submit a semiannual report due to excess emission and monitoring systems performance over the three-year period.

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Sheet 6: Respondents

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	660	0	0	660
2	0	660	0	0	660
3	0	660	0	0	660
Average	0	660	0	0	660
a New respondents include sources with constructed and reconstructed affected facilities.