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	20
Number of Respondents	167
Total Estimated Burden Hours	6,630
Total Estimated Costs	$990,000
Annualized Capital O&M	$154,000
Total Annual Responses	335
Form Number	Not Applicable

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Sheet 2: Table 1

Table 1: Annual Respondent Burden and Cost - NSPS for Calciners and Dryers in Mineral Industries (40 CFR Part 60, Subpart UUU) (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 person- hours per year (E=CxD)	(F) Management person hours per year (Ex0.05)	(G) Clerical person hours per year (Ex0.1)	(H) Cost, $ b
1. Reporting requirements										Labor Rates
A. Familiarization with regulatory requirementsc	1	1	1	167	167	8	17	$24,216.59		Management	$163.17
B. Required Activities										Technical	$130.28
Initial performance test d	330	1	330	0	0	0	0	$0		Clerical	$65.71
Repeat performance test e	330	1	330	0	0	0	0	$0
Scrubber demonstration f	2	1	2	0	0	0	0	$0
Reference Method 9 text g,h	18	1	18	0	0	0	0	$0
Re-calibration of continuous opacity monitors (COM) i	4	2	8	0	0	0	0	$0
Re-calibration of scrubber i,j	4	2	8	0	0	0	0	$0
C. Create Information	See 3B
D. Gather existing information	See 3B
E. Write report
Notification of construction/reconstruction or modification	2	1	2	0	0	0	0	$0
Notification of actual startup	2	1	2	0	0	0	0	$0
Notification of demonstration of CMS	2	1	2	0	0	0	0	$0
Notification of physical or operation change k	2	1	2	1	2	0	0	$290.02
Notification of initial performance test	2	1	2	0	0	0	0	$0
Notification of repeat performance test	2	0.2	0.4	0	0	0	0	$0
Performance test report	8	1	8	0	0	0	0
Semiannual reports l	16	2	32	167	5,344	267	534	$774,930.77
Subtotal for Reporting Requirements					6,340			$799,437
2. Recordkeeping requirements
A. Familiarization with Regulatory Requirements c	See 3A
B. Plan activities	See 3B
C. Implement activities	See 3B
D. Develop record system	N/A
E. Time to enter information
Records of startup, shutdowns, malfunctions m	1.5	1	1.5	167	250.5	12.525	25.05	$36,324.88
F. Train to train personnel	N/A
G. Audits	N/A
Subtotal for Recordkeeping Requirements					288			$36,325		20	hr/response
Total Labor Burden and Costs (rounded) n					6,630			$836,000
Total Capital and O&M Cost (rounded) n								$154,000
GRAND TOTAL (rounded) n								$990,000
Assumptions:
a We have assumed that the average number of respondents that will be subject to the rule over the three-year period of this ICR will be 167. It is estimated that no additional respondents will become subject to the regulation in 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 assume that each respondent will have to familiarize with the regulatory requirements each year.
d We have assumed that it will take 330 hours to complete a performance test.
e We have assumed that 20 percent of new respondents will have to conduct a CMS demonstration.
f We have assumed that 20 percent of new respondents will take two hours to conduct a scrubber demonstration.
g We have assumed that 80 percent of new respondents will conduct a reference Method 9 test.
h We have assumed that it will take respondents 18 hours to conduct a reference Method 9 test.
i We have assumed that it will take 4 hours to re-calibrate either the COM or the scrubber.
j We have assumed that 20 percent of new respondents will re-calibrate the scrubber.
k We have assumed that one respondent will notify the Agency regarding a physical or operational change.
l We have assumed that it will take 16 hours for each respondent to complete the semiannual report of exceedances.
m We have assumed that it will take each respondent 1.5 hours to record SSM information.
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 - NSPS for Calciners and Dryers in Mineral Industries (40 CFR Part 60, Subpart UUU) (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 person- hours per year (E=CxD)	(F) Management person hours per year (Ex0.05)	(G) Clerical person hours per year (Ex0.1)	(H) Cost, $ b
Initial performance tests										Labor Rates
New or modified facility	40	1	40	0	0	0	0	$0		Management	$73.46
Repeat performance tests					0	0	0	$0		Technical	$54.51
New or modified facility	40	0.2	8	0	0	0	0	$0		Clerical	$29.50
Report review					0	0	0	$0
New or modified facility					0	0	0	$0
Modification of construction/reconstruction or modification	2	1	2	0	0	0	0	$0
Notification of actual startup	2	1	2	0	0	0	0	$0
Notification of demonstration of CMS	2	1	2	0	0	0	0	$0
Notification of physical or operational change c	2	1	2	1	2	0.1	0.2	$122.27
Notification of initial performance test	2	1	2	0	0	0	0	$0
Review demonstration of CMS d	4	1	4	0	0	0	0	$0
Review test results e	8	1.2	9.6	0	0	0	0	$0
Review of semiannual report of exceedances f	8	2	16	167	2672	133.6	267.2	$163,347.38
TOTAL (rounded) g					3,080			$163,000
Assumptions:
a We have assumed that the average number of respondents that will be subject to the rule over the three-year period of this ICR will be 167. It is estimated that no additional respondents will become subject to the regulation in 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 one respondent will submit a notification of physical or operational change.
d We have assumed that it will take four hours to review the CMS demonstration report.
e We have assumed that it will take eight hours to review the performance test results.
f We have assumed that it will take eight hours to review semiannual report of exceedances.
g 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)			2008 Average CEPCI	2022 CEPCI
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, (E X F)			575.4	816
CMS	$5,673	0	$0	$922	167	$154,000
Totals (rounded) b			$0			$154,000		$154,000
a Costs have been increased from 2008 to 2022 $ using the CEPCI Equipment Cost Index.
b Totals have been rounded to 3 significant digits. 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/reconstruction or modification	0	0	0	0
Notification of actual startup	0	0	0	0
Notification of demonstration of CMS	0	0	0	0
Notification of physical or operational change	1	1	0	1
Notification of initial performance test	0	0	0	0
Notification of the repeat of the performance test	0	0	0	0
Repeat of performance test results	0	0	0	0
Semiannual reports	167	2	0	334
			Total	335

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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	167	0	0	167
2	0	167	0	0	167
3	0	167	0	0	167
Average	0	167	0	0	167
a New respondents include sources with constructed and reconstructed affected facilities.