Burden Calculation Table

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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	60
Number of Respondents	1
Total Estimated Burden Hours	120
Total Estimated Costs	$22,400
Annualized Capital O&M	$8,400
Total Annual Responses	2
Form Number	Not Applicable

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Sheet 2: Table 1

Table 1: Annual Respondent Burden and Cost – NSPS for Phosphate Rock Plants (40 CFR Part 60, Subpart NN) (Renewal)
Burden Item	(A) Person- hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person- hours per respondent per year (AxB)	(D) Respondents per yeara	(E) Technical person- hours per year (CxD)	(F) Management person-hours per year (Ex0.05)	(G) Clerical person-hours per year (Ex0.1)	(H) Cost b ($)
1. Applications	N/A									Labor Rates
2. Survey and Studies	N/A									Management	$157.61
3. Reporting requirements										Technical	$123.94
A. Familiarization with Regulatory Requirements	1	1	1	1	1	0.05	0.10	$138.07		Clerical	$62.52
B. Required activities
Initial emissions tests	32	1	32	0	0	0	0	0
Report performance test c	32	1	32	0	0	0	0	0
C. Create Information	See 3B
D. Gather existing information	See 3B
E. Write report
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 physical or operational change which may increase the emission rate d	2	1	2	0	0	0	0	0
Notification of CMS demonstration e	2	1	2	0	0	0	0	0
Notification of initial performance test	2	1	2	0	0	0	0	0
Report of initial performance test	2	1	2	0	0	0	0	0
Semiannual report on excess emissions f	8	2	16	1	16	0.80	1.60	$2,209.18
Reporting Subtotal					20			$2,347
4. Recordkeeping requirements
A. Familiarization with Regulatory Requirements	See 3E
B. Plan activities	See 3E
C. Implement activities	See 3E
D. Develop record system	See 3E
E. Time to enter information
Record operating parameters g	0.25	350	87.5	1	87.50	4.38	8.75	$12,081.47
F. Time to transmit or disclose information	N/A
G. Train personnel	N/A
H. Audits	N/A
Recordkeeping Subtotal					101			$12,081
TOTAL ANNUAL BURDEN AND COST (Rounded) h					120			$14,000
TOTAL CAPITAL AND O&M COSTS (Rounded) h								$8,400
GRAND TOTAL (Rounded) h								$22,400
						60	hr/response
Assumptions:
a We have assumed that the average number of respondents that will be subject to the rule will be one, with no new sources expected to become subject to the rule over the three-year period of this ICR.
b This ICR uses the following labor rates: Managerial $157.61 ($75.05 + 110%); Technical $123.94 ($59.02 + 110%); and Clerical $62.52 ($29.77 + 110%). 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.
c We have assumed that 20 percent of initial performance test will be repeated due to failure.
d We have assumed that no facility will be engaged in physical or operational changes.
e We have assumed that it will take each respondent 2 hours each to write CMS notification report.
f We have assumed that each respondent will take 8 hours, two times per year, to write semiannual report on excess emissions.
g We have assumed that each respondent will take 15 minutes per day to record operating parameters information.
h Totals are rounded to three 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 Phosphate Rock Plants (40 CFR Part 60, Subpart NN) (Renewal)
Activity	(A) EPA person- hours per occurrence	(B) No. of occurrences per plant per year	(C) EPA person- hours per plant per year (AxB)	(D) Plants per year a	(E) Technical person- hours per year (CxD)	(F) Management person-hours per year (Ex0.05)	(G) Clerical person-hours per year (Ex0.1)	(H) Cost b ($)
Initial performance tests										Labor Rates
New or modified facility	24	1	24	0	0	0	0	0		Management	$70.56
Repeat performance test										Technical	$52.37
New or modified facility c	24	1	24	0	0	0	0	0		Clerical	$28.34
Report Review
New or modified facility
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 physical or operational change which may increase the emission rate d	2	1	2	0	0	0	0	0
Notification of CEMS demonstration e	2	1	2	0	0	0	0	0
Notification of initial performance test	2	1	2	0	0	0	0	0
Report on initial performance test	8	1	8	0	0	0	0	0
Semiannual report on excess emissions f	4	2	8	1	8	0.4	1	$469.86
TOTAL (Rounded) g					10			$470
Assumptions:
a We have assumed that the average number of respondents that will be subject to the rule will be one, with no new sources expected to 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 $70.56 (GS-13, Step 5, $44.10 + 60%); Technical $52.37 (GS-12, Step 1, $32.73 + 60%); and Clerical $28.34 (GS-6, Step 3, $17.17 + 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), 2022 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 20 percent of initial performance test will be repeated due to failure.
d We have assumed that no facility will be engaged in physical or operational changes.
e We have assumed that it will take each respondent 2 hours each to review CMS notification report.
f We have assumed that each respondent will take 8 hours two times per year to review semiannual report on excess emissions.
g Totals are rounded to three significant figures. Figures may not add up 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 a	Total Capital/Startup Cost, (B X C) b	Annual O&M Costs for One Respondent	Number of Respondents with O&M	Total O&M, (E X F) b
Continuous Opacity Monitor	$37,000	0	$0	$8,400	1	$8,400
Total			$0			$8,400
a It is assumed that one new source will become subject to the rule over the three-year period of this ICR.
b Totals have been rounded to three significant figures. Figures may not add exactly due to rounding.
					C/S and O&M	$8,400

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Sheet 5: Responses

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 construction or modification	0	1	N/A	0
Notification of actual startup	0	1	N/A	0
Notification of physical or operational change which may increase the emission rate	0	1	N/A	0
Notification of demonstration of CMS	0	1	N/A	0
Notification of initial performance tests	0	1	N/A	0
Report of initial performance test	0	1	N/A	0
Semiannual report on excess emissions	1	2	N/A	2
			TOTAL (rounded)	2

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Sheet 6: Respondents

Number of Respondents
	Respondents that submit reports		Respondents that do not submit any reports
Year	(A) Number of New Respondents 1	(B) Number of Existing Respondents	(C) Number of Existing Respondents that keep records but do not submit reports	(D) Number of Existing Respondents that are also new respondents	(E) Number of Respondents (E=A+B+C+D)
1	0	1	0	0	1
2	0	1	0	0	1
3	0	1	0	0	1
Average	0	1	0	0	1
1 New respondents include sources with constructed, reconstructed, and modified affected facilities