Burden Tables

2485t05.xlsx

NSPS for Kraft Pulp Mills for which Construction, Reconstruction or Modification Commenced after May 23, 2103 (40 CFR part 60, subpart BBa) (Renewal)

Burden Tables

OMB: 2060-0690

Document [xlsx]
Download: xlsx | pdf

Overview

Summary
Table 1
Table 2
Capital O&M
Respondents
Responses


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

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.



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.



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.

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.

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.
File Typeapplication/vnd.openxmlformats-officedocument.spreadsheetml.sheet
File Modified0000-00-00
File Created0000-00-00

© 2024 OMB.report | Privacy Policy