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	52
Number of Respondents	35
Total Estimated Burden Hours	2,840
Total Estimated Costs	$4,690,000
Annualized Capital O&M	$4,330,000
Total Annual Responses	55
Form Number	Not Applicable

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Sheet 2: Table 1

Table 1: Annual Respondent Burden and Cost – NSPS for Nitric Acid Plants (40 CFR Part 60, Subparts G and Ga) (Renewal)
					130.28	163.17	65.71
Burden Item	(A) Respondent Hours per Occurrence	(B) Number of Occurrences per Respondent per Year	(C) Hours per Respondent per Year (C=AxB)	(D) Number of Respondents per Year a	(E) Technical Hours per Year (E=CxD)	(F) Management Hours per Year (F=Ex0.05)	(G) Clerical Hours per Year (G=Ex0.1)	(H) Total Labor Costs per Year, b
1. Applications	N/A
2. Survey and Studies	N/A
3. Reporting Requirements
Sources Constructed or Modified after 10/14/2011 – Subpart Ga
A. Familiarize with regulatory requirements c	1	1	1	11	11	0.55	1.1	$1,595.10
B. Required Activities
Initial performance test	180	1	180	1.2	216	10.8	21.6	$31,322.05
Demonstration of CERMS	180	1	180	1.2	216	10.8	21.6	$31,322.05
Repeat performance test d	180	1	180	0.24	43.2	2.16	4.32	$6,264.41
Daily monitoring of CERMS	0.5	330	165	1.2	198	9.9	19.8	$28,711.88
C. Create Information	See 3B
D. Gather Existing Information	See 3E
E. Write Report
Notification of construction/reconstruction	2	1	2	1.2	2.4	0.12	0.24	$348.02
Notification of actual startup	2	1	2	1.2	2.4	0.12	0.24	$348.02
Notification of initial performance test	2	1	2	1.2	2.4	0.12	0.24	$348.02
Notification of demonstration of CERMS	2	1	2	1.2	2.4	0.12	0.24	$348.02
Report of performance test	2	1	2	1.2	2.4	0.12	0.24	$348.02
Report of noncompliance with NOX emission standard e	2	1	2	1.1	2.2	0.11	0.22	$319.02
Subtotal for Reporting Requirements - Subpart Ga					803			$101,275
Existing Sources – Subpart G
A. Familiarize with regulatory requirements c	1	1	1	24	24	1.2	2.4	$3,480.23
B. Write Report
Notification of physical/operational changes f	See 3E
Semiannual reports g	8	2	16	24	384	19.2	38.4	$55,683.65
Subtotal for Reporting Requirements- Subpart G					469			$59,164
Total Reporting Requirements for Subparts G and Ga					1,270			$160,000
4. Recordkeeping Requirements
A. Familiarize with regulatory requirements	See 3A
B. Plan activities	See 3B
C. Implement activities	See 3B
D. Develop record system	N/A
Subpart Ga: Sources Constructed or Modified after 10/14/2011
E Time to Enter Information
Records of noncompliance e	0.5	1	0.5	1.1	0.55	0.03	0.06	$79.76
Daily production and flow rates	8	1	8	11	88	4.4	8.8	$12,760.84
Data collection	0.13	330	41.25	11	453.75	22.69	45.38	$65,798.06
Records of occurrence of startup, shutdown and malfunctions	8	1	8	11	88	4.4	8.8	$12,760.84
F. Time to Train Personnel
Train personnel for CERMS maintenance	16	2	32	11	352	17.6	35.2	$51,043.34
Subtotal for Recordkeeping Requirements - Subpart Ga					1130			$142,443
Subpart G: Existing Sources
E. Time to Enter Information
Records of daily production rates and hours of operation	8	1	8	24	192	9.6	19.2	$27,841.82
Records of occurrence of startup, shutdown and malfunctions	8	1	8	24	192	9.6	19.2	$27,841.82
Records of performance test data	80	1	80	0	0	0	0	$0
G. Audits	N/A
Subtotal for Recordkeeping Requirements - Subpart G					442			$55,684
Total Recordkeeping Requirements for Subparts G and Ga					1571			$198,100
Total Labor Burden and Cost for Subpart Ga (rounded) h					1,930			$244,000
Total Labor Burden and Cost for Subpart G (rounded) h					911			$115,000
TOTAL LABOR BURDEN AND COST (rounded) h					2,840			$359,000
TOTAL CAPITAL AND O&M COST (rounded) h								$4,330,000				52	hrs per response
GRAND TOTAL (rounded) h								$4,690,000
Assumptions
a We have assumed there are approximately 35 respondents (24 subject to Subpart G and 11 subject to Subpart Ga), with 1.2 new sources per year becoming subject to the rule over the next three years.
b This ICR uses the following labor rates: $130.28 for technical, $163.17 for managerial, and $65.71 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2022, “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 each respondent will have to familiarize with regulatory requirements each year.
d We assume that 20% of sources will have to repeat performance tests.
e We assume 10% of sources will report non-compliance.
f We assume 1 existing facility will be reconstructed or modified over the next 5 years (0.2 respondents per year).
g We assume it will take 8 hours to write semiannual reports.
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 Nitric Acid Plants (40 CFR Part 60, Subparts G and Ga) (Renewal)
					54.51	73.46	29.50
Burden Item	(A) EPA Hours per Occurrence	(B) Number of Occurrences per Plant per Year	(C) EPA Hours per Respondent per Year (C=AxB)	(D) Number of Respondents per Year a	(E) Technical Hours per Year (E=CxD)	(F) Management Hours per Year (F=Ex0.05)	(G) Clerical Hours per Year (G=Ex0.1)	(H) Total Labor Costs per Year, b
Subpart Ga a
Required Activities
Observe initial performance test	24	1	24	1.2	28.8	1.44	2.88	$1,760.63
Repeat performance test c	24	0.2	4.8	0.24	1.15	0.06	0.12	$70.43
Report Review					0	0	0	$0.00
Notification of construction/reconstruction	2	1	2	1.2	2.4	0.12	0.24	$146.72
Notification of actual startup	0.5	1	0.5	1.2	0.6	0.03	0.06	$36.68
Notification of initial performance test	0.5	1	0.5	1.2	0.6	0.03	0.06	$36.68
Review test results	8	1	8	1.2	9.6	0.48	0.96	$586.88
Review test NOX noncompliance reports d	8	1	8	1.1	8.8	0.44	0.88	$537.97
Subtotal for Subpart Ga					60			$3,176
Subpart G
Report Review
Semiannual reports a	2	2	4	24	96	4.8	9.6	$5,868.77
Subtotal for Subpart G					110			$5,870
TOTAL ANNUAL BURDEN and COST (rounded) e					170			$9,050
Assumptions
a We have assumed there are approximately 35 respondents (24 subject to Subpart G and 11 subject to Subpart Ga), with 1.2 new sources per year becoming subject to the rule over the next three years.
b This ICR uses the following average hourly labor rates: $73.46 for managerial (GS-13, Step 5, $45.91 + 60%), $54.51 (GS-12, Step 1, $34.07 + 60%) for technical and $29.50 (GS-6, Step 3, $18.44 + 60%) for clerical. These rates are from the Office of Personnel Management (OPM), 2023 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% of new sources will have to repeat performance tests.
d We assume 10% of sources will report non-compliance.
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

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 d	Number of New Respondents	Total Capital/Startup Cost, (B X C)	Annual O&M Costs for One Respondent d	Number of Respondents with O&M	Total O&M, (E X F)
Subpart G										816	2022 CE Index Value
NOx CMS	$105,611	0	$0	$155,310	24	$3,727,446				567.3	2013 CE Index Value
Subpart Ga										525.4	2007 CE Index Value
NOx CERMSa,b	$163,226	1.2	$195,871	$33,785	11	$371,635
CERMS testing	$21,603	1.2	$25,924	NA	0	NA
Flow meter testing	$8,960	1.2	$10,752	NA	0	NA
File cabinets	$1,126	1.2	$1,352	NA	0	NA
Totals (rounded) c			$234,000			$4,100,000		$4,330,000
a We estimate an annual capital cost of $163,226 for NOx CERMS and $1,126 for file cabinets for all respondents. The capital cost per respondent is calculated by dividing the total capital cost by 1.2 new respondents.
b On average over the three-year period of this ICR, we estimate an average 11 respondents per year will be subject to Subpart Ga (a growth rate of 1.2 respondents per year).
c Totals have been rounded to 3 significant digits. Figures may not add exactly due to rounding.
d Costs have been updated to 2022 $ using the CEPCI Equipment Cost Index.

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Sheet 5: 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	1.2	33	0	0.2	34
2	1.2	34	0	0.2	35
3	1.2	35	0	0.2	36
Average	1.2	34	0	0	35
a New respondents include sources with constructed, reconstructed and modified affected facilities. In this standard existing respondents submit initial notifications.

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Sheet 6: 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
Subpart Ga
Notification of construction/reconstruction	1.2	1	0	1.2
Notification of actual startup	1.2	1	0	1.2
Notification of initial performance test	1.2	1	0	1.2
Notification of CERMS demonstration	1.2	1	0	1.2
Report of performance test	1.2	1	0	1.2
Report of noncompliance with NOx emission standard	1.1	1	0	1.1
Subpart G
Notification of physical/operational changes	0	1	0	0
Semiannual reports	24	2	0	48
			Total	55