Burden Calculation Tables

1130t13..xlsx

NSPS for Grain Elevators (40 CFR part 60, subpart DD) (Renewal)

Burden Calculation Tables

OMB: 2060-0082

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Overview

Summary
Table 1
Table 2
Capital O&M
Responses
Respondents


Sheet 1: Summary

ICR Summary Information
Hours per Response 2.3
Number of Respondents 200
Total Estimated Burden Hours 460
Total Estimated Costs $55,000
Annualized Capital O&M $0
Total Annual Responses 200

Sheet 2: Table 1

Table 1: Annual Respondent Burden and Cost – NSPS for Grain Elevators (40 CFR Part 60, Subpart DD) (Renewal)














Burden item (A) (B) (C) (D) (E) (F) (G) (H)


Person hours per occurrence No. of occurrences per respondent per year Person hours per respondent per year Respondents per year a Technical person- hours per year Management person hours per year Clerical person hours per year Total Cost per year b




(C=AxB)
(E=CxD) (Ex0.05) (Ex0.1)

Labor Rates:
1. Applications N/A







Management $157.61
2. Survey and Studies N/A







Technical $123.94
3. Reporting requirements








Clerical $62.52
A. Read and understand rule requirement 1 1 1 200 200 10 20 $27,615


B. Required activities










Initial performance tests c 28 1 28 0 0 0 0 $0


Repeat performance tests d 28 0.2 5.6 0 0 0 0 $0


C. Create information See 3B









D. Gather existing information See 3B









E. Write report e










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 results 2 1 2 0 0 0 0 $0


Notification of repeat performance test results See 3B









Report of performance test results 8 1.2 9.6 0 0 0 0 $0


Subtotal for Reporting Requirements



230 $27,615


4. Recordkeeping requirements










A. Read and understand rule requirement See 3A









B. Plan activities See 3B









C. Implement Activities See 3B









D. Develop record system N/A









E. Time to enter and transmit information










Records of startup, shutdown, malfunction f 1 1 1 200 200 10 20 $27,615


F. Time to train personnel N/A









G. Time for audits N/A









Subtotal for Recordkeeping Requirements



230 $27,615


Total Labor Burden and Costs (rounded) g



460 $55,000


Total Capital and O&M Cost (rounded) g






$0


GRAND TOTAL (rounded) g






$55,000
2.3
Assumptions:








hr/response
a We have assumed that there are approximately 200 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three years.


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 have assumed that it will take twenty-eight hours for each new respondent to perform the initial performance test.


d We have assumed that 20 percent of respondents would repeat performance test due to failure.


e Applies to new or reconstructed sources. There are no additional new or reconstructed sources anticipated to become subject to the rule over the next three years.


f We have assumed that each respondent will take one hour to record information on startup, shutdown, malfunction.


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



Sheet 3: Table 2

Table 2: Average Annual EPA Burden and Cost - NSPS for Grain Elevators (40 CFR Part 60, Subpart DD) (Renewal)














Activity (A) (B) (C) (D) (E) (F) (G) (H)


EPA person- hours per occurrence No. of occurrences per plant per year EPA person- hours per plant per year Plants per year a Technical person- hours per year Management person-hours per year Clerical person-hours per year Cost, $ b




(C=AxB)
(E=CxD) (Ex0.05) (Ex0.1)



Initial performance tests c 24 1 24 0 0 0 0 $0
Labor Rates:
Repeat performance test d 24 0.2 4.8 0 0 0 0 $0
Management $70.56
Report Review








Technical $52.37
Notification of construction 2 1 2 0 0 0 0 $0
Clerical $28.34
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


Total Annual Burden and Cost (rounded) e



0 $0














Assumptions:










a We have assumed that there are approximately 200 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three years.


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, $44.10 + 60%), Technical rate of $52.37 (GS-12, Step 1, $32.73 + 60%), and Clerical rate of $26.34 (GS-6, Step 3, $17.17 + 60%). These rates are from the Office of Personnel Management (OPM) “2022 General Schedule” which excludes locality rates of pay.


c We have assumed that it will take twenty-four hours for each new respondent to perform the initial performance test.


d We have assumed that 20 percent of new respondents would repeat performance test due to failure.


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



Sheet 4: Capital O&M

The only type of industry costs associated with the information collection activity in the regulations are labor costs. There are no capital/startup or operation and maintenance costs.

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
Notification of construction/reconstruction 0 1 0 0
Notification of actual startup 0 1 0 0
Notification of initial performance test 0 1 0 0
Report of performance tests results 0 1.2 0 0
Records of SSM 0 0 200 200



Total 200





a We have assumed that there are approximately 200 respondents subject to the rule, with no new sources expected over the next three-years of this ICR.

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 0 200 0 0 200
2 0 200 0 0 200
3 0 200 0 0 200
Average 0 200 0 0 200
a New respondents include sources with constructed, reconstructed, and modified affected facilities.




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