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 Lime Manufacturing (40 CFR Part 60, Subpart HH) (Renewal)
					122.66	149.84	60.88
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 Annual Cost, $ b
1. Applications	N/A
2. Survey and Studies	N/A
3. Reporting Requirements
A. Familiarize with regulatory requirements c	1	1	1	41	41	2.05	4.1	$5,585.84
B. Required activities:
Initial performance tests d	280	1	280	0	0	0	0	$0
Reference Method 9 Test e	4	1.2	4.8	0	0	0	0	$0
Repeat of performance test f	280	0.2	56	0	0	0	0	$0
C. Create information	See 3B
D. Gather Existing Information	See 3B
E. Write report
Notification of construction/reconstruction	2	1	2	0	0	0	0	$0
Notification of actual startup	2	1	2	0	0	0	0	$0
Notification of any physical or operational change	2	1	2	0	0	0	0	$0
Notification of demonstration of continuous monitoring system	2	1	2	0	0	0	0	$0
Notification of initial performance test	2	1	2	0	0	0	0	$0
Notification that continuous monitoring system (CMS)	2	1	2	0	0	0	0	$0
Performance test results	See 3B
Semiannual excess emissions reports g	8	2	16	41	656	32.8	65.6	$89,373.44
Subtotal for Reporting Requirements					802			$94,959
4. Recordkeeping requirements
A. Familiarize with regulatory requirements	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 CMS operating parameters h	0.25	250	62.5	41	2,562.5	128.13	256.25	$349,115.00
Records of startup, shutdown, malfunction i	1.5	1	1.5	41	61.5	3.08	6.15	$8,378.76
F. Time to train personnel	N/A
G. Time for audits	N/A
Subtotal for Recordkeeping Requirements					3,018			$357,494		responses	hr/response
TOTAL LABOR BURDEN AND COST (rounded) j					3,820			$452,000		82	47
TOTAL CAPITAL AND O&M COST (rounded) j								$61,500
GRAND TOTAL (rounded) j								$514,000
Assumptions:
a We have assumed that the average number of respondents that will be subject to the rule will be 41, and 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: $149.84 per hour for Executive, Administrative, and Managerial labor; $122.66 per hour for Technical labor, and $60.88 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 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% to account for the benefit packages available to those employed by private industry.
c We have assumed that all respondents will have to familiarize with the regulatory requirements each year.
d We have assumed that it will take 280 hours to complete a performance test.
e It will take respondents 4 hours to conduct a reference Method 9 test.
f We have assumed that 20 percent of new respondents will have to repeat the performance test.
g We have assumed that it will take 8 hour two times per year for each respondent to complete the semiannual report of exceedances.
h We have assumed that it will take 15 minutes, 250 days per year to record CMS operating parameters information.
i We have assumed that it will take 1.5 hours once a year to record information on startup, shutdown, and malfunction
j 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 Lime Manufacturing (40 CFR Part 60, Subpart HH) (Renewal)
					51.23	69.04	27.73
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=Ex0.10)	Cost, $ b
Activity:
Initial performance tests c	38	1	38	0	0	0	0	$0
Repeat performance test d	38	0.2	7.6	0	0	0	0	$0
Report Review:
Notification of construction/reconstruction e	2	1	2	0	0	0	0	$0
Notification of actual startup	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 demonstration of CMS	0.5	1	0.5	0	0	0	0	$0
Notification of CMS data to determine compliance	0.5	1	0.5	0	0	0	0	$0
Performance test results g	8	1.2	9.6	0	0	0	0	$0
Semiannual report h	4	2	8	41	328	16.4	32.8	$18,845.24
TOTAL ANNUAL BURDEN AND COST (rounded) i					377			$18,800
Assumptions:
a We have assumed that the average number of respondents that will be subject to the rule will be 41, and 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 labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: Managerial rate of $69.04 (GS-13, Step 5, $43.15 + 60%), Technical rate of $51.23 (GS-12, Step 1, $32.02 + 60%), and Clerical rate of $27.73 (GS-6, Step 3, $17.33 + 60%). These rates are from the Office of Personnel Management (OPM) “2021 General Schedule” which excludes locality rates of pay.
c We have assumed that it will take 38 hours to observe an initial performance test.
d We have assumed that 20 percent of new respondents will have to repeat the performance test.
e It will take 2 hours to review construction/reconstruction report.
f It will take 0.5 hours to review the physical or operational change review.
g We have assumed that it will take 8 hours to review the performance test results report.
h We have assumed that it will take 4 hour to review each semiannual reports.
i Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.