Burden Calculation Tables

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Overview

# Respondents
# Responses
Respondent Burden
Agency Burden

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Sheet 1: # 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	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	20	0	1	20
2	1	20	0	1	20
3	1	20	0	1	20
Average	1	20	0	1	20
1 New respondents include sources with constructed, reconstructed, and modified affected facilities.

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Sheet 2: # Responses

Total Annual Responses
(A) Information Collection Activity	(B) Number of Respondents	(C) Number of Responses	(D) Number of Existing Respondents That Keep Records But Do Not Submit Reports	(E) Total Annual Responses E=(BxC)+D
Notification of construction/reconstruction	1	1	0	1
Notification of actual startup	1	1	0	1
Notification of initial performance test	1	1	0	1
Notification of CMS demonstration	1	1	0	1
Report of performance test (includes CMS demonstration report)	1	1	0	1
Semiannual scrubber report	20	2	0	40
			Total	45

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Sheet 3: Respondent Burden

Table 1: Annual Respondent Burden and Cost – NSPS for Metallic Mineral Processing Plants (40 CFR Part 60, Subpart LL) (Renewal)
Burden item										TECH	$112.98
Burden item	(A) Person-hours per occurrence	(B) Annual occurrences per respondent	(C) Person-hours per respondent per year (AxB)	(D) Respondents per year a	(E) Technical hours per year (CxD)	(F) Management hours per year (Ex0.05)	(G) Clerical hours per year (Ex0.10)	(H) Annual cost ($) b		MGMT	$149.35
1. Applications	N/A									CLER	$54.81
2. Surveys and studies	N/A
3. Reporting requirements
A. Familiarization with regulatory requirements	1	1	1	Tracy Curtis: Update to # of existing respondents - per the ERG guidance doc, if submittals are less often than bi-monthly, then existing sources would have a small burden here. 20	20	1.00	2.00	2,518.57		Source Type	No.
B. Required activities										Existing	20
Initial performance test	330	1	330	1	330	16.5	33	41,556.41		Modified	1
Repeat performance test c	330	1	330	0.2	66	3.3	6.6	8,311.28		New	0
C. Create information	See 3B
D. Gather existing information	See 3B
E. Write report
Notification of construction/reconstruction	2	1	2	1	2	0.1	0.2	251.86
Notification of actual startup	2	1	2	1	2	0.1	0.2	251.86
Notification of initial performance test	2	1	2	1	2	0.1	0.2	251.86
Report of performance test	See 3B
Notification of CMS demonstration	2	1	2	1	2	0.1	0.2	251.86
Report of CMS demonstration	See 3B
Semiannual scrubber report	8	2	16	20	320	16	32	40,297.12
Subtotal for Reporting Requirements					856			93,691
4. Recordkeeping requirements
A. Familiarization with regulatory 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	0.25	250	62.5	20	1,250	62.5	125	157,411
Records of startup, shutdown, malfunction	1.5	1	1.5	20	30	1.5	3	3,777.86
F. Train personnel	N/A
G. Audits	N/A
Subtotal for Recordkeeping Requirements					1,472			161,188
TOTAL LABOR BURDEN AND COST (rounded)d					2,330			$255,000			52 hrs/resp
TOTAL CAPITAL AND O&M COST (rounded)d								$13,000
GRAND TOTAL (rounded)d								$268,000			52
Assumptions:
a On average, EPA estimates 20 existing sources will be subject to the NSPS. No new sources will become subject to the standard over the three-year period of this ICR. EPA also estimates one existing facility will undergo either a reconstruction or a physical or operational change such that it will be required to submit initial notifications and conduct initial performance testing.
b This ICR uses the following labor rates: $112.98 (technical), $149.35 (managerial), and $54.81 (clerical). These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2017, “Table 2. Civilian workers, by occupational and industry group.” The rates are from column 1, “Total compensation.” They have been increased by 110 percent to account for the benefit packages available to those employed by private industry.
c EPA assumes 20 percent of respondents will have to repeat the performance test due to failure.
d Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 4: Agency Burden

Table 2: Average Annual EPA Burden and Cost – NSPS for Metallic Mineral Processing Plants (40 CFR Part 60, Subpart LL) (Renewal)
										TECH	$48.08
Burden item	(A) EPA person-hours per occurrence	(B) Annual occurrences per respondent	(C) EPA person-hours per respondent per year (AxB)	(D) Respondents per year a	(E) Technical hours per year (CxD)	(F) Management hours per year (Ex0.05)	(G) Clerical hours per year (Ex0.10)	(H) Annual cost ($) b		MGMT	$64.80
Performance test review										CLER	$26.02
Initial performance test	24	1	24	1	24	1.2	2.4	1,294.13
Repeat performance test c	24	1	24	0.2	4.8	0.24	0.48	258.83
Report review
Notification of construction/reconstruction	2	1	2	1	2	0.1	0.2	107.84
Notification of actual startup	0.5	1	0.5	1	0.5	0.03	0.05	26.96
Notification of initial performance test	0.5	1	0.5	1	0.5	0.03	0.05	26.96
Report of performance test (includes CMS demonstration report)	8	1	8	1	8	0.4	0.8	431.38
Notification of CMS demonstration	0.5	1	0.5	1	0.5	0.03	0.05	26.96
Semiannual scrubber report	4	2	8	20	160	8	16	8,627.52
TOTAL LABOR BURDEN AND COST (ROUNDED)d					230			$10,800
a On average, EPA estimates 20 existing sources will be subject to the NSPS. No new sources will become subject to the standard over the three-year period of this ICR. EPA also estimates one existing facility will undergo either a reconstruction or a physical or operational change such that it will be required to submit initial notifications and conduct initial performance testing.
b This ICR uses the following labor rates: $48.08 (technical), $64.80 (managerial), and $26.02 (clerical). These rates are from the Office of Personnel Management (OPM), 2017 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 EPA assumes 20 percent of respondents will have to repeat the performance test due to failure.
d Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.