Burden Calculation Tables

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Overview

Summary
Table 1
Table 2
Capital O&M
Respondents
Responses

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Sheet 1: Summary

ICR Summary Information
Hours per Response	79
Number of Respondents	12
Total Estimated Burden Hours	4,250
Total Estimated Costs	$1,000,000
Annualized Capital O&M	$487,000
Total Annual Responses	54
Form Number	Not Applicable

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Sheet 2: Table 1

Table 1: Annual Respondent Burden and Cost – Kraft Pulp Mill Affected Sources for Which Construction, Reconstruction, or Modification Commenced After May 23, 2013 (40 CFR Part 60, Subpart BBa) (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 (C=AxB)	Respondents per year a	Technical person- hours per year (E=CxD)	Management person hours per year (F=Ex0.05)	Clerical person hours per year (G=Ex0.1)	Total cost per year b
1. Applications	N/A									Labor Rates
2. Survey and studies	N/A									Management	$157.61
3. Reporting requirements										Technical	$123.94
A. Familiarize with regulatory requirements c	30	1	30	12	360	18	36	$49,706.62		Clerical	$62.52
B. Required activities
Initial performance tests d	80	1	80	0	0	0	0	$0.00
5-year repeat performance tests d, e	80	1	80	2	160	8	16	$22,091.83
Repeated performance tests due to failure d, f	80	0.2	16	0.4	6	0.3	0.6	$883.67
C. Gather existing information	See 3B
D. Write report
Notification of construction/reconstruction	2	1	2	0	0	0	0	$0.00
Notification of performance test f	2	1.2	2.4	2.4	6	0.3	0.6	$795.31
Notification of actual startup	2	1	2	0	0	0	0	$0.00
Notification of CMS demonstration	2	1	2	0	0	0	0	$0.00
Notification of physical or operational changes	2	1	2	0	0	0	0	$0.00
Notification of opacity observations	2	1	2	0	0	0	0	$0.00
Report of performance test (including submittal through EPA's ERT) f, g	4	1.2	4.8	2.4	12	0.6	1.2	$1,590.61
Semiannual report h, i	8	2	16	12	192	10	19	$26,510.20
Excess emissions/monitoring systems report i, j	20	2	40	12	480	24	48	$66,275.50
Malfunction report (affirmative defense) k	30	2	60	0	0	0	0	$0
Subtotal for Reporting Requirements					1,398			$167,854
4. Recordkeeping requirements
A. Read instructions	See 3A
B. Plan activities	See 3B
C. Implement activities	See 3B
D. Develop record system l	40	1	40	0	0	0	0	$0.00
E. Time to enter and transmit information
Records of monitoring data m	0.5	365	182.5	12	2,190	110	219	$302,381.95
Records of malfunctions	2	12	24	12	288	14	29	$39,765.30
Subtotal for Recordkeeping Requirements					2,850			$342,147
TOTAL LABOR BURDEN AND COST (rounded) n					4,250			$510,000		79	hrs/response
TOTAL CAPITAL AND O&M COST (rounded) n								$487,000
GRAND TOTAL (rounded) n								$1,000,000
Assumptions:
a We assume 12 mills per year will be subject to the rule with no additional respondents.
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 assume that each respondent will have to familiarize with the regulatory requirements each year.
d We assume it will take 80 hours for each respondent to coordinate the performance tests for PM, CPM, opacity and TRS. Testing contractor costs are included in the capital/startup and O&M costs.
e Repeat performance tests are required in 5-year intervals. We assume 2 respondents per year will be required to conduct repeat performance tests.
f We assume that 20 percent of respondents would repeat a performance test due to failure.
g Hard copy report of performance test is included in 3B. Submittal of performance test data through EPA's ERT is estimated to require 4 hours per test.
h Assumes that it will take each respondent 8 hours to complete the semiannual report.
i Ongoing activities are based on the average number of respondents per year over the 3-year ICR periods.
j We assume each respondent will take 20 hours two times per year to review monitoring data (e.g., to document compliance with allowances) and complete the excess emissions report.
k Not applicable.
l Includes time to adjust existing data acquisition systems at modified sources to include startup and shutdown periods and comply with revised monitoring allowances; this is a one-time activity.
m We assume that it will take each respondent 30 minutes per day to document monitoring data (e.g., operating parameters, opacity and TRS monitoring data, CMS performance evaluations, and startup/shutdown).
n 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 – Kraft Pulp Mill Affected Sources for Which Construction, Reconstruction, or Modification Commenced After May 23, 2013 (40 CFR Part 60, Subpart BBa) (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 (C=A×B)	Plants per year a	Technical person- hours per year (E=C×D)	Management person-hours per year (F=E×0.05)	Clerical person-hours per year (G=E×0.1)	Cost b
1. Attend initial performance test c	24	1	24	0	0	0	0	$0.00		Labor Rates
2. Attend 5-year repeat performance test c, d	24	1	24	2	48	2.4	4.8	$2,819.14		Management	$70.56
3. Attend repeat performance test due to failure c, e	24	0.2	4.8	0.4	1.92	0.096	0.192	$112.77		Technical	$52.37
4. Report review										Clerical	$28.34
Review notification of construction/reconstruction	2	1	2	0	0	0	0	$0.00
Review notification of performance test e	0.5	1.2	0.6	2.4	1.44	0.072	0.144	$84.57
Review notification of actual startup	0.5	1	0.5	0	0	0	0	$0.00
Review notification of CMS demonstration	0.5	1	0.5	0	0	0	0	$0.00
Review notification of physical/operational changes	0.5	1	0.5	0	0	0	0	$0.00
Review notification of opacity observations	0.5	1	0.5	0	0	0	0	$0.00
Review performance test reports e	8	1.2	9.6	2.4	23	1.2	2.3	$1,353.19
Review semiannual report f, g	4	2	8	12	96	4.8	10	$5,638.27
Review excess emissions/monitoring systems report f, g	8	2	16	12	192	10	19	$11,276.54
TOTAL (rounded)h					417			$21,300
Assumptions:
a We assume 12 mills per year will be subject to the rule with no additional respondents.
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 assume that it will take EPA personnel 24 hours to attend each performance test.
d Repeat performance tests are required in 5-year intervals. We assume 2 respondents per year will be required to conduct repeat performance tests.
e We assume that 20 percent of respondents would repeat a performance test due to failure.
f We assume that it will take EPA personnel 4 hours to review each semiannual report and 8 hours to review each excess emissions report and malfunction report.
g Ongoing activities are based on the average number of respondents per year over the 3-year ICR periods.
h Totals have been rounded to 3 significant figures.

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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	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)
Opacity monitor	$40,000	0	$0	$8,600	12	$103,200
TRS monitor	$108,000	0	$0	$23,000	12	$276,000
ESP voltage and current monitors	$31,000	0	$0	$4,200	12	$50,400
Scrubber pressure drop monitor a	$350	0	$0	$70	12	$840
Scrubber liquid flow rate monitor a	$15,500	0	$0	$3,100	12	$37,200
Performance tests:
Initial Method 9 for opacity	$1,000	0	$0
Initial Method 5 and 202 for PM and condensable PM (CPM)	$6,800	0	$0
Initial Method 16, 16A, 16B or 16C for TRS	$3,000	0	$0
Repeat Method 5 and 202 for PM and CPM (every 5 years) b	N/A			$6,800	2	$13,600
Repeat Method 16, 16A, 16B or 16C for TRS (every 5 years) b	N/A			$3,000	2	$6,000
Total c			$0			$487,000
a Scrubber monitor O&M costs were estimated as 20 percent of the initial monitor cost.
b Repeat tests are required in 5-year intervals. We assume that 2 respondents per year will be required to conduct repeat performance tests.
c Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 5: Respondents

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	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	12	0	0	12
2	0	12	0	0	12
3	0	12	0	0	12
Average	0	12	0	0	12
a New respondents include sources with constructed, reconstructed and modified affected facilities.

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Sheet 6: 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 performance test a	2.4	1.2	0	2.88
Notification of actual startup	0	1	0	0
Notification of CMS demonstration	0	1	0	0
Notification of physical or operational changes	0	1	0	0
Notification of opacity observations	0	1	0	0
Report of performance test (including submittal through EPA's ERT) a	2.4	1.2	0	2.88
Semiannual report	12	2	0	24
Excess emissions/monitoring systems report	12	2	0	24
			Total	54
a We assume that there are no new respondents each year and that two existing respondents will have to complete the 5-year repeat performance tests during the three-year period of this ICR. We also assume that 20% of respondents will have to repeat a performance test due to failure.