Burden Calculations Table

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Overview

Table 1
Table 2

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Sheet 1: Table 1

Table 1: Annual Respondent Burden and Cost – NSPS for Glass Manufacturing Plants (40 CFR Part 60, Subpart CC) (Renewal)
					121.46	148.45	60.23
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
2. Survey and Studies	N/A
3. Reporting Requirements
A. Familiarization with rule requirements c	1	1	1	41	41	2.05	4.1	$5,531.13
B. Required Activities
Initial performance test d	160	1	160	0	0	0	0	$0
Repeat of performance test e	160	0.2	32	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 f	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 g	2	1	2	0	0	0	0	$0
Notification of initial performance test	2	1	2	0	0	0	0	$0
Performance test report	See 3B
Demonstration of CMS	See 3B
Request for alternative CMS	4	1	4	0	0	0	0	$0
Routine maintenance report h	2	1	2	21	42	2.1	4.2	$5,666.03
Semiannual report	8	2	16	41	656	32.8	65.6	$88,498.01
Subtotal for Reporting Requirements					850			$99,695
4. Recordkeeping requirements
A. Familiarization with rule requirements	See 3A
B. Plan activities	See 3B
C. Implement activities	See 3B
D. Develop record system	N/A
E. Time to enter information	See 3E
F. Train personnel	N/A
G. Audits	N/A
Subtotal for Recordkeeping Requirements					0			$0		responses	hr/response
TOTAL LABOR BURDEN AND COST (rounded) i					850			$99,700		103	8
TOTAL CAPITAL AND O&M COST (rounded) i								$238,000
GRAND TOTAL (rounded) i								$338,000
Assumptions:
a We have assumed that the number of existing respondents is 41, and that no additional new sources will become subject to the rule over the three-year period of this ICR.
b This ICR uses the following labor rates: $148.45 per hour for Executive, Administrative, and Managerial labor; $121.46 per hour for Technical labor, and $60.23 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2020, “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 the benefit packages available to those employed by private industry.
c We have assumed that it will take one hour for all existing respondents to familiarize with regulatory requirements.
d We have assumed that it will take 160 hours to complete a performance test.
e We have assumed that 20 percent will fail the performance tests.
f We have assumed that it will take two hours to write notification of actual startup report.
g We have assumed that it will take two hours to write notification report of physical or operation change.
h We have assumed that 50 percent of respondents will submit routine maintenance reports.
i Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 2: Table 2

Table 2: Average Annual EPA Burden and Cost – NSPS for Glass Manufacturing Plants (40 CFR Part 60, Subpart CC) (Renewal)
					50.72	68.37	27.46
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 (F=Ex0.05)	Clerical person-hours per year (G=Ex0.1)	Cost, $ b
Initial performance tests
New or modified facility c	40	1	40	0	0	0	0	$0
Repeat performance test
New or modified facility c, d	40	0.2	8	0	0	0	0	$0
Report review
New or Modified Facility
Modification of construction/ reconstruction or modification e	2	1	2	0	0	0	0	$0
Notification of actual startup f	0.5	1	0.5	0	0	0	0	$0
Notification of demonstration of CMS f	0.5	1	0.5	0	0	0	0	$0
Notification of physical or operational change f	0.5	1	0.5	0	0	0	0	$0
Notification of initial performance test f	0.5	1.2	0.6	0	0	0	0	$0
Review of performance test results g	8	1.2	9.6	0	0	0	0	$0
Review demonstration of CMS	See "Review of performance test results"
Review request for alternative CMS	4	1	4	0	0	0	0	$0
Review of routine maintenance report h	2	1	2	21	42	2.1	4.2	$2,389.15
Review of semiannual reports	4	2	8	41	328	16.4	32.8	$18,658.12
TOTAL LABOR BURDEN AND COST (rounded) i					426			$21,000
Assumptions:
a We have assumed that the average number of existing respondents is 41, and that no additional new sources will become subject to the rule over the three-year period of this ICR.
b This cost is based on the following hourly labor rates times a 1.6 benefits multiplication factor to account for government overhead expenses: $68.37 for Managerial, $50.72 for Technical, and $27.46 for Clerical. These rates are from the Office of Personnel Management (OPM) “2020 General Schedule” which excludes locality rates of pay.
c We have assumed that it will take 40 hours to participate with the performance tests.
d We have assumed that 20 percent of respondents will repeat performance tests because of failure.
e We have assumed that it will take two hours to review construction report.
f It will take each respondent 0.5 hours to review actual startup report, CMS report, physical or operational change report, and initial performance test report.
g We have assumed that it will take eight hours to review performance test results.
h We have assumed that 50 percent of respondents will submit routine maintenance reports.
i Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.