Burden Calculations Table

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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	127
Number of Respondents	53
Total Estimated Burden Hours	13,500
Total Estimated Costs	$2,110,000
Annualized Capital O&M	$416,000
Total Annual Responses	106
Form Number	Not Applicable

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Sheet 2: Table 1

Table 1: Annual Respondent Burden and Cost – NSPS for Sulfuric Acid Plants (40 CFR Part 60, Subpart H) (Renewal)
Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C = A x B)	(D) Respondents per year a	(E) Technical person- hours per year (E = C x D)	(F) Management person hours per year (E x 0.05)	(G) Clerical person hours per year (E x 0.1)	(H) Total Cost Per year b
1. Applications	N/A									Labor Rates
2. Survey and Studies	N/A									Management	$163.17
3. Reporting requirements										Technical	$130.28
A. Familiarization with rule requirements c	1	1	1	53	53	2.65	5.3	$7,685.50		Clerical	$65.71
B. Required activities
Initial performance tests d	300	1	300	0	0	0	0	$0
Reference Method 9 test e	4	1	4	0	0	0	0	$0
Repeat of performance tests f	300	1	300	0	0	0	0	$0
C. Create information	See 3B
D. Gather existing information	See 3B
E. Write Report
Application of construction or modification	2	1	2	0	0	0	0	$0
Notification of actual startup	2	1	2	0	0	0	0	$0
Notification of physical or operational change	2	1	2	0	0	0	0	$0
Notification of demonstration of CMS	2	1	2	0	0	0	0	$0
Notification of initial performance test	2	1	2	0	0	0	0	$0
Semiannual report of excess emissions g	40	2	80	53	4,240	212	424	$614,840.28
Subtotal for Reporting Requirements					4,937			$622,526
4. Recordkeeping requirements
A. Familiarization with rule requirements	See 3A
B. Plan activities	See 3A
C. Implement Activities	See 3A
D. Develop record system	N/A
E. Time to enter information
Records of operating parameters h	0.25	350	87.5	53	4637.5	231.88	463.75	$672,481.56
Record of conversion factors/calculation i	0.05	1,050	52.5	53	2782.5	139.13	278.25	$403,488.93
F. Time to train personnel	N/A
G. Time for audits	N/A
Subtotal for Recordkeeping Requirements					8,533			$1,075,970
Total Labor Burden and Costs (rounded) j					13,500			$1,700,000		Responses	106
Total Capital and O&M Cost (rounded) j								$416,000		Hours/response	127
GRAND TOTAL (rounded) j					13,500			$2,110,000
Assumptions:
a We have assumed that there are approximately 53 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three years.
b This ICR uses the following labor rates: Managerial $163.17 ($77.70 + 110%); Technical $130.28 ($62.04 + 110%); and Clerical $65.71 ($31.29 + 110%). 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 it will take one hour for each respondent to read instructions.
d We have assumed that it will take 300 hours for each respondent to complete an initial performance test.
e We have assumed that it will take four hours for each respondent to complete a reference Method 9 test.
f We have assumed that it will take 300 hours to repeat performance test due to failures.
g We have assumed that it will take 40 hours, twice a year, for each respondent to write an excess emission report.
h We have assumed that each respondent will enter information on records of operating parameters 350 times per year.
i We have assumed that records of conversion factors will be recorded three times daily, at 350 days per year, for a total of 3 x 350 = 1,050 times per year.
j 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 Sulfuric Acid Plants (40 CFR Part 60, Subpart H) (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=AxB)	Plants per year a	Technical person- hours per year (E=CxD)	Management person-hours per year (Ex0.05)	Clerical person-hours per year (Ex0.1)	Cost, $ b
New facility										Labor Rates
Initial performance test c	50	1	50	0	0	0	0	$0		Management	$73.46
Repeat performance test/observed d	24	1	24	0	0	0	0	$0		Technical	$54.51
Review reports										Clerical	$29.50
Notification of construction	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 test	0.5	1.2	0.6	0	0	0	0	$0
Review test results	8	1.2	9.6	0	0	0	0	$0
Notification of CMS demonstration	0.5	1	0.5	0	0	0	0	$0
Existing facility	0.5	1	0.5	0	0	0	0	$0
Excess emission reports e	4	2	8	53	424	21.2	42.4	$25,920.39
TOTAL (rounded) f					488			$25,900
Assumptions:
a We have assumed that there are approximately 53 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three years.
b This cost is based on the average hourly labor rate as follows: Managerial $73.46 (GS-13, Step 5, $45.91 + 60%); Technical $54.51 (GS-12, Step 1, $34.07 + 60%); and Clerical $29.50 (GS-6, Step 3, $18.44 + 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), 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 that it will take fifty hours for Agency observation of the initial performance test.
d We have assumed that it will take twenty-four hours for Agency observation of a repeat of the performance test due to failure.
e We have assumed that it will take four hours, twice per year, to review the excess emission reports.
f 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 a	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	Total O&M, (ExF)		CEPCI Index
CMS	$209,141	0	$0	$7,843	53	$415,669		Year	Index
SO2 testing	$13,943	0	$0	$0	0	$0		2005	468.2
Total b			$0			$416,000		2022	816
a Capital/Startup and Annual O&M costs have been increased from 2005 to 2022 $ using the CEPCI Index.
b 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	Number of Responses	Number of Existing Respondents That Keep Records But Do Not Submit Reports	Total Annual Responses E=(BxC)+D
Notification of construction or modification	0	1	0	0
Notification of actual startup	0	1	0	0
Notification of physical or operational change	0	1	0	0
Notification of demonstration of CMS	0	1	0	0
Notification of initial performance test	0	1	0	0
Semiannual report of excess emissions	53	2	0	106
			Total	106

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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	53	0	0	53
2	0	53	0	0	53
3	0	53	0	0	53
Average	0	53	0	0	53
a New respondents include sources with constructed, reconstructed, and modified affected facilities.