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	65
Number of Respondents	535
Total Estimated Burden Hours	69,100
Total Estimated Costs	$8,290,000
Annualized Capital O&M	$0
Total Annual Responses	1,070
Form Number	Not Applicable

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Sheet 2: Table 1

Table 1: Annual Respondent Burden and Cost – NSPS for Stationary Gas Turbines (40 CFR Part 60, Subpart GG) (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 (F=Ex0.05)	(G) Clerical person hours per year (G=Ex0.1)	Total Cost Per year ($) b
1. Applications	N/A									Labor Rates
2. Surveys and studies	N/A									Management	$157.61
3. Reporting requirements										Technical	$123.94
A. Familiarize with regulatory requirements c	1	1	1	535	535	26.75	53.5	$73,869.56		Clerical	$62.52
B. Required activities d
Initial performance test	110	1	110	0	0	0	0	$0
Repeat performance test e	110	0.2	22	0	0	0	0	$0
C. Create information	See 3B
D. Gather existing information	See 3E
E. Write report
Notification of construction/reconstruction d	2	1	2	0	0	0	0	$0
Notification of actual startup d	2	1	2	0	0	0	0	$0
Notification of initial performance test d	2	1.2	2.4	0	0	0	0	$0
Notification of demonstration of CMS d	2	1	2	0	0	0	0	$0
Report of performance test	See 3B
Excess emission and exemption reports f	10	2	20	535	10,700	535	1,070	$1,477,391
Subtotal for Reporting Requirements					12,920			$1,551,261
4. Recordkeeping Requirements
A. Familiarize with regulatory requirements c	See 3A
B. Plan activities	See 4C
Implement activities	See 3
Develop record system	N/A
C. Time to check computer system and calibrate continuous monitor g	0.25	365	91.25	535	48,818.75	2,440.94	4,881.88	$6,740,598
D. Train personnel	N/A
E. Audits	N/A
Subtotal for Recordkeeping Requirements					56,142			$6,740,598
TOTAL LABOR BURDEN AND COST (rounded) h					69,100			$8,290,000	65	hr/response
TOTAL CAPITAL AND O&M COST (rounded) h								$0
GRAND TOTAL (rounded) h								$8,290,000
Assumptions:
a We have assumed that the average number of respondents that will be subject to the rule will be 535 existing sources. There will be no additional sources 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 all respondents will have to familiarize with the regulatory requirements each year.
d We have assumed that there will be no new sources expected over the three-year period of this ICR.
e We have assumed that 20 percent of respondents will have to repeat initial performance test due to failure.
f We have assumed that each respondent will take 10 hours two times per year to write the excess emissions and exemption reports.
g We have assumed that it will take each respondent 15 minutes 365 days per year to check computer system and calibrate continuous monitor.
h 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 Gas Turbines (40 CFR Part 60, Subpart GG) (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 (F=Ex0.05)	(G) Clerical person-hours per year (G=Ex0.1)	(H) Cost per year, ($) b
1. Performance test										Labor Rates
New plants c	24	1.2	28.8	0	0	0	0	$0		Management	$70.56
2. Report review										Technical	$52.37
Notification of construction c	2	1	2	0	0	0	0	$0		Clerical	$28.34
Notification of actual startup c	0.5	1	0.5	0	0	0	0	$0
Notification of initial test c	0.5	1	0.5	0	0	0	0	$0
Notification of CMS demonstration c	0.5	1	0.5	0	0	0	0	$0
3. Semiannual reports
Excess emissions and exemption reports d	4	2	8	535	4,280	214	428	$251,373
TOTAL (rounded) e					4,920			$251,000
Assumptions:
a We have assumed that the average number of respondents that will be subject to the rule will be 535 existing sources. There will be no additional sources 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, $17.71 + 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 there will be no new sources expected over the three-year period of this ICR
d We have assumed that it will take 4 hours two times per year to review the excess emissions and exemption reports.
e 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	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	1.2	0	0
Notification of demonstration of CMS	0	1	0	0
Excess emission and exemption (semiannual) report	535	2	0	1,070
Total Number of Annual Responses			Total	1,070

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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 1	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	535	0	0	535
2	0	535	0	0	535
3	0	535	0	0	535
Average	0	535	0	0	535
1 New respondents include sources with constructed, reconstructed and modified affected facilities.