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	16
Number of Respondents	33
Total Estimated Burden Hours	2,670
Total Estimated Costs	$408,000
Annualized Capital O&M	$72,400
Total Annual Responses	166
Form Number	Not Applicable

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Sheet 2: Table 1

Table 1: Annual Respondent Burden and Cost – NESHAP for Beryllium (40 CFR Part 61, Subpart C) (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 hours per year (E=CxD)	(F) Management hours per year (F=Ex0.05)	(G) Clerical hours per year (G=Ex0.1)	(H) Total cost per year b ($)
1. Applications										Labor Rates
A. Application for approval of construction/modification	4	1	4	0	0	0	0	$0		Management	$163.17
B. Request for ambient air monitoring alternative	4	1	4	0	0	0	0	$0		Technical	$130.28
2. Surveys and studies	N/A									Clerical	$65.71
3. Reporting requirements
A. Familiarize with regulatory requirements c	1	1	1	33	33	1.65	3.3	$4,785.31
B. Required activities
i. Initial emissions test	20	1	20	0	0	0	0	$0
ii. Determine emission level from stack test d	8	1	8	23	184	9.2	18.4	$26,681.75
iii. Monitoring of ambient beryllium concentrations	See 3E
C. Create information	See 3E
D. Gather existing information	See 3E
E. Write report
i. Notification of actual startup	2	1	2	0	0	0	0	$0
ii. Notification of stack test e	2	1	2	23	46	2.3	4.6	$6,670.44
iii. Report of emission level determination/operational change f	8	1	8	23	184	9.2	18.4	$26,681.75
iv. Plan for locating monitors	16	1	16	0	0	0	0	$0
v. Report monthly ambient concentrations g	8	12	96	10	960	48	96	$139,209.12
Subtotal for Reporting Requirements					1,618			$204,028
4. Recordkeeping requirements
A. Read instructions	See 3A
B. Plan activities	See 4C
C. Implement activities	See 3B
D. Develop record system	N/A
E. Time to enter information
i. Records of operating parameters and emissions h	0.25	365	91.25	10	912.5	45.63	91.25	$132,321.17
F. Time to train personnel	N/A
G. Time for audits	N/A
Subtotal for Recordkeeping Requirements					1,049			$132,321		responses	hr/response
TOTAL LABOR BURDEN AND COST (rounded) i					2,670			$336,000		166	16.0843373493976
TOTAL CAPITAL AND O&M COST (rounded) i								$72,400
GRAND TOTAL (rounded) i								$408,000
Assumptions:
a For the purpose of determining recordkeeping and reporting burdens associated with this rule, we have assumed there are 33 respondents, and that no new additional sources will be subject over the three-year period of this ICR. Of a total of approximately 236 existing sources, we have assumed approximately 10 sources have elected to comply with the rule by monitoring ambient air beryllium concentrations and that the remaining 226 sources have complied by conducting a one-time-only stack test. We also have assumed that 10 percent of the 226 sources (i.e., 23 respondents) will engage in operational changes that will require them to repeat stack testing and to carry out subsequent recordkeeping and reporting requirements.
b This ICR uses the following labor rates: $163.17 ($77.70 + 110%) per hour for Executive, Administrative, and Managerial labor; $130.28 ($62.04 + 110%) per hour for Technical labor, and $65.71 ($31.29 + 110%) per hour 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 all existing respondents will have to familiarize with the regulatory requirements each year.
d We have assumed that each respondent will take eight hours to determine the emission level from the stack test.
e We have assumed that each respondent will take two hours to write notification report of stack test.
f We have assumed that each respondent will take eight hours to complete the report of emission level determination/operational change.
g We have assumed that each respondent will take eight hours once per month to write the monthly ambient concentrations report.
h We have assumed that each of the ten respondents will take fifteen minutes each day to enter records of operating parameters and emissions information.
i 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 – NESHAP for Beryllium (40 CFR Part 61, Subpart C) (Renewal)
Burden Item	(A) Technical person-hours per occurrence	(B) No. of occurrences per respondent per year	(C) Technical person-hours per respondent per year (C=AxB)	(D) 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)	Total cost per year ($) b
Initial performance test										Labor Rates
New plant	20	1	20	0	0	0	0	$0		Management	$73.46
Report review										Technical	$54.51
Notification of construction	2	1	2	0	0	0	0	$0		Clerical	$29.50
Request to use ambient air concentration alternative	2	1	2	0	0	0	0	$0
Notification of actual startup	0.5	1	0.5	0	0	0	0	$0
Notification of initial stack test	0.5	1	0.5	0	0	0	0	$0
Report of initial analysis	2	1	2	0	0	0	0	$0
Existing plant
Notification of stack test	40	1	40	23	920	46	92	$56,242.36
Report of emission level determination/operational change c	2	1	2	23	46	2.3	4.6	$2,812.12
Report of monthly ambient concentrations d	2	12	24	10	240	12	24	$14,671.92
TOTAL (rounded) e					1,390			$73,700
Assumptions:
a For the purpose of determining recordkeeping and reporting burdens associated with this rule, we have assumed there are 33 respondents, and that no new additional sources will be subject over the three-year period of this ICR. Of a total of approximately 236 existing sources, we have assumed approximately 10 sources have elected to comply with the rule by monitoring ambient air beryllium concentrations and that the remaining 226 sources have complied by conducting a one-time-only stack test. We also have assumed that 10 percent of the 226 sources (i.e., 23 respondents) will engage in operational changes that will require them to repeat stack testing and to carry out subsequent recordkeeping and reporting requirements.
b The cost is based on the following labor rates: Managerial rate of $73.46 (GS-13, Step 5, $45.91 + 60%), Technical rate of $54.51 (GS-12, Step 1, $34.07 + 60%), and Clerical rate of $29.50 (GS-6, Step 3, $18.44 + 60%). 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 have assumed it will take two hours per respondent to review the emission level determination/operational change report.
d We have assumed it will take two hours per respondent per month to review the monthly ambient concentrations report.
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	Number of New Respondents	Total Capital/Startup Cost, (B X C)	Annual O&M Costs for One Respondent a	Number of Respondents with O&M b	Total O&M, (E X F)			2001 Average CEPCI	2022 CEPCI
Ambient monitor	$0	0	$0	$7,243	10	$72,432			394.3	816
Totals (rounded) c			$0			$72,400		$72,400
a Costs have been increased from 2001 to 2022 $ using the CEPCI Equipment Cost Index.
b We have assumed approximately 10 sources have elected to comply with the rule by monitoring ambient air beryllium concentrations and that the remaining 226 sources have complied by conducting a one-time-only stack test.
c Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 5: 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
Notification of stack test	23	1	0	23
Emission level/operational changes	23	1	0	23
Monthly ambient concentrations	10	12	0	120
			Total	166

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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 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	33	0	0	33
2	0	33	0	0	33
3	0	33	0	0	33
Average	0	33	0	0	33
a New respondents include sources with constructed, reconstructed, and modified affected facilities.