Burden Calculation Tables

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Overview

Summary
Table 1
Table 2
Capital O&M
Responses
Respondents

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Sheet 1: Summary

ICR Summary Information
Hours per Response	42
Number of Respondents	871
Total Estimated Burden Hours	90,300
Total Estimated Costs	$10,800,000
Annualized Capital O&M	$0
Total Annual Responses	2135
Form Number	Not Applicable

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Sheet 2: Table 1

Table 1: Annual Respondent Burden and Cost – NSPS for Stationary Combustion Turbines (40 CFR Part 60, Subpart KKKK) (Renewal)
										123.94	157.61	62.52
Burden item	(A) Person hours per occurrence	(B) No. 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) Total Cost per year, $ b
1. Applications	N/A
2. Surveys and studies	N/A
3. Reporting requirements
A. Familiarization with Regulatory Requirements c	4	1	4	871	3,484	174.2	348.4	$481,044.59
B. Required activities
- Performance test d	12	1	12	237	2,849	142.5	284.9	$393,402.22
- Fuel sampling – dual fuel turbines e	0.5	52	26	126	3,288	164.4	328.8	$454,027.02
- Fuel sampling – distillate oil only turbines f	0.5	5	2.5	8	20.9	1.04	2.09	$2,882.97
C. Gather existing information	See 3D
D. Write report
Notification of construction/ reconstruction g, h	2	1	2	47	94	4.7	9.4	$12,978.82
Notification of actual startup g, h	2	1	2	47	94	4.7	9.4	$12,978.82
Notification of performance test d	2	1	2	237	474.9	23.7	47.5	$65,567.04
Notification of demonstration of CEMS i	2	1	2	15	30	1.5	3	$4,142.18
Initial notification of compliance g, h	2	1	2	47	94	4.7	9.4	$12,978.82
Semiannual Compliance report j, k	8	2	16	871	13,936	696.8	1393.6	$1,924,178.36
Subtotal for Reporting Requirements					28,020			$3,364,181
4. Recordkeeping requirements
A. Familiarization with Regulatory Requirement c	See 3A
B. Train personnel h	40	1	40	47	1,880	94	188	$259,576.30
C. Continuous monitoring
- Record information k, l	5	12	60	871	52,260	2,613	5,226	$7,215,668.85
Subtotal for Recordkeeping Requirements					62,261			$7,475,245
TOTAL LABOR BURDEN AND COST (rounded)m					90,300			$10,800,000				90,300
Capital and O&M Costm								$0
Grand Totalm								$10,800,000			42	hr/response
Assumptions:
a We have assumed that there is an annual average of 871 sources currently subject to the regulations, including 824 existing respondents, and an additional 47 respondents per year who will become subject to the standards. This ICR assumes the industry continues to grow at a constant rate since the previous renewal.											777 was 683 before
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 percent to account for varying industry wage rates and the additional overhead business costs of employing workers beyond their wages and benefits, including business expenses associated with hiring, training, and equipping their employees.												871
c We have assumed that it will take 4 hours for respondents to familiarize with regulatory requirements and that all sources will have to familiarize with requlatory requirements.												824 average was 730 before
d We have assumed that 237 respondents will each take 12 hours to conduct annual stack testing to demonstrate compliance with NOx emission limitation.											was 199	3.67	237
e We have assumed that 126 respondents will each take 0.5 hours 52 times per year to complete fuel sampling for the dual fuel turbines.											was 106	6.89	126
f We have assumed that eight respondents will each take 0.5 hours 5 times per year to complete the fuel sampling for the distillate oil only turbines.											was 7	104	8
g We have assumed that it will take each new respondent 2 hours to write notification report.
h We have assumed that this is a one-time report for new respondents.
i We have assumed that of the 47 new respondents each year, 15 of these respondents will write reports demonstrating CEMS compliance.
j We have assumed that each of the respondents will take 8 hours twice per year to write the compliance report.
k The average number of existing respondents is 824.
l We have assumed that it will take each respondent 5 hours twelve times per year to record information.
m Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: Table 2

Table 2: Average Annual EPA Burden and Cost – NSPS for Stationary Combustion Turbines (40 CFR Part 60, Subpart KKKK)(Renewal)
											52.37	70.56	28.34
Activity	(A) EPA person- hours per occurrence	(B) No. of occurrences per plant per year	(C) EPA person- hours per plant per year (C=AxB)	(D) Plants 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
Report Review
1. Notification of construction/reconstruction c	1	1	1	47	47	2.35	4.7	$2,760.40
2. Notification of actual startup d	0.5	1	0.5	47	23.5	1.18	2.35	$1,380.20
3. Notification of performance test	2	1	2	237	470	23.5	47.0	$27,604.04
4. Notification of demonstration of CEMS e	2	1	2	15	30	1.5	3	$1,761.96
5. Initial notification of compliance	2	1	2	47	94	4.7	9.4	$5,520.81
6. Semiannual compliance report f	2	1	2	871	1742	87.1	174	$102,311.14
TOTAL ANNUAL BURDEN AND COST (rounded)g					2,770			$141,000
Assumptions:
a We have assumed that there is an average of 824 sources currently subject to the regulations and an additional 47 respondents per year will become subject. The ICR assumes the industry continues to grow at a constant rate since the previous renewal.
b This ICR uses the following labor rates: $70.56 per hour for Managerial labor; $52.37 per hour for Technical labor, and $28.34 per hour for Clerical labor. These rates are from the Office of Personnel Management (OPM), 2022 General Schedule, which excludes locality rates of pay. The rates have been increased by 60% to account for the benefit packages available to government employees.
c We have assumed that new respondents will take one hour each to review the notification of construction/reconstruction report.
d We have assumed that it will take 0.5 hours for new respondents to review the actual startup report.
e We have assumed that of the 47 new respondents, only 15 of these respondents will review the notification of demonstration of CEMS report.
f We have assumed that it will take 2 hours once per year to review the compliance report.
g 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

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.

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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
Notification of construction/reconstruction	47	1	0	47
Notification of actual startup	47	1	0	47
Notification of performance test	237	1	0	237
Notification of demonstration of CEMS	15	1	0	15
Initial notification of compliance	47	1	0	47
Semiannual compliance report	871	2	0	1742
			Total	2135

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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	47	777	0	0	824
	2	47	824	0	0	871
	3	47	871	0	0	918
	Average	47	824	0	0	871