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 – NESHAP for Engine Test Cells/Stands (40 CFR Part 63, Subpart PPPPP) (Renewal)
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 (Ex0.05)	(G) Clerical person hours per year (Ex0.1)	(H) Total Cost per year b
1. Applications	N/A									Labor Costs
2. Surveys and studies	N/A									Managerial	$153.55
3. Reporting requirements										Technical	$122.20
A. Familiarization with regulatory requirements a	4	1	4	8	32	1.6	3.2	$4,352.91		Clerical	$61.51
B. Notifications c
Initial notifications c	2	1	2	0.67	1.33	0.07	0.13	$181.19
Notification of construction/reconstruction	2	1	2	0	0	0	0	$0
Notification of actual startup	2	1	2	0	0	0	0	$0
C. Create information	See 3B
D. Gather existing information	See 3E
E. Write report
Compliance status report d	4	2	8	8	64	3	6	$8,705.82
Performance evaluation report	16	1	16	0	0	0	0	$0
Subtotal for Reporting Requirements					112			$13,240
4. Recordkeeping requirements
A. Initial performance evaluation e	330	1	330	0	0	0	0	$0
B. Monitoring demonstration e	148	1	148	0	0	0	0	$0
C. Repeat performance evaluation e	330	1	330	0	0	0	0	$0
D. Maintain records of CEMS performance f	1.5	52	78	8	624	31.2	62.4	$84,881.78
Subtotal for Recordkeeping Requirement					718			$84,882
Total Labor Burden and Costs (rounded) g						830		$98,100
Total Capital and O&M Cost (rounded) g								$2,400		17	# responses
GRAND TOTAL (rounded) g								$101,000		49	hours/response
Assumptions:
a We assume that the average number of respondents subject to the rule will be 8, and that no new facilities will become subject to the recordkeeping and reporting requirements of the rule over the three-year period of this ICR. This ICR assumes that all sources will incur a burden to re-familiarize themselves with the regulatory requirements each year.
b This ICR uses the following labor rates: $122.20 (technical), $153.55 (managerial), and $61.51 (clerical). 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.” They have been increased by 110 percent to account for the benefit packages available to those employed by private industry.
c We assume that two new sources will be constructed over the next three years that will be subject only to the initial notification requirement in §63.9345(b)(3) and §63.9(b)(2)(i) through (v).
d Compliance status reports are required semiannually. We assume that deviations get reported as part of the semiannual compliance status report.
e We assume there are no new respondents required to perform the initial performance evaluation, monitoring demonstration, or repeat performance evaluation due to failure.
f We assume that owners and operators will maintain CEMS monitoring records on a weekly basis.
g 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 - NESHAP for Engine Test Cells/Stands (40 CFR Part 63, Subpart PPPPP) (Renewal)
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 (Ex0.05)	(G) Clerical person-hours per year (Ex0.1)	(H) Total Cost, $ b
1. Attend CEMS performance evaluation	32	1	32	0	0	0	0	$0		Labor Rates
2. Repeat performance evaluation										Managerial	$69.04
A. Retesting preparation	12	1	12	0	0	0	0	$0		Technical	$51.23
B.  Attend retesting	32	1	32	0	0	0	0	$0		Clerical	$27.73
3. Deviation – enforcement activities c	16	1	16	2	32	1.6	3.2	$1,838.56
4. Reporting requirements
A.  Review waivers d	2	2	4	0	0	0	0	$0
B.   Review reports
Review initial notifications	2	1	2	0.67	1.33	0.07	0.13	$76.53
Compliance status report e	2	2	4	8	32	1.6	3.2	$1,838.56
Performance evaluation report	2	1	2	0	0	0.0	0	$0
TOTAL ANNUAL BURDEN AND COST (rounded)f					75			$3,750
Assumptions:
a We assume that the average number of respondents subject to the rule will be 8, and that no new facilities will become subject to the recordkeeping and reporting requirements of the rule over the three-year period of this ICR.
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), 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 assume that 20 percent of all respondents will be out of compliance.
d We assume that none of the respondents are submitting waivers for recordkeeping and reporting requirements.
e Compliance status reports review is required semiannually. We assume that deviations get reported as part of the semiannual compliance status report.
f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: O&M

Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
Year	(A)	(B)	(C)	(D)	(E)
	Number of New Respondents a	Number of Existing Respondents b	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	8	0	0	8
2	0	8	0	0	8
3	0	8	0	0	8
Average	0	8	0	0	8
a New respondents include sources with constructed, reconstructed and modified affected facilities.
b Two additional sources are expected to become subject to the rule over the three-year period of this ICR but are expected to be subject only to the initial notification requirements and therefore, are not included in this table. These two additional sources are not subject to emission limits, performance testing, recordkeeping, and reporting requirements.
Capital/Startup vs. 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)
Thermocouples for CPMS	$500	0	$0	$300	8	$2,400
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
Compliance status report	8	2	0	16
Initial notifications	1	0.67	0	0.67
Notification of construction/reconstruction	1	0	0	0
Notification of actual startup	1	0	0	0
Performance evaluation report	1	0	0	0
			Total (rounded)	17