Burden calculation tables

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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	8
Number of Respondents	Stacie Enoch: Based on EPA consult response, there are 60-70 existing facilities, 16 new per year due to growth/significant changes in utility sector. I started with 60 (went with low end since we're doubling the previous estimate), works out to be an overall avg of 92 over 3 years. Tried to confirm EPA's estimates with CAMD and EIA datasets. Sounds like Christian was using CAMD data for the 60-70 estimate, and I see fewer than that if I specifically look at records flagged for Subpart TTTT (closer to the original estimate of 32). Sarah Downes (ERG) is CAMD expert, and says records flagged for Subpart TTTT is likely an underestimate because it's only showing the subset of Subpart TTTT facilities (see Sarah's response saved on S drive in consults folder). Unable to find subparts listed in a few EIA datasets. Checked a crosswalk of CAMD to EIA units (https://www.epa.gov/airmarkets/power-sector-data-crosswalk, Excel download saved on S drive) and found ~84 unique facilities that are operating as of 2015 (rule is applicable to units that commenced construction after January 8, 2014, wasn't sure how soon they'd start operating), and there are probably other filters that would be needed to narrow down the 84 to Subpart TTTT facilities... All this to say, I think Christian's estimate of 60-70 existing sources is probably a reasonable estimate in between my CAMD underestimate and crosswalk overestimate. 92
Total Estimated Burden Hours	3,130
Total Estimated Costs	$376,000
Annualized Capital O&M	$0
Total Annual Responses	400
Form Number	Not Applicable

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Sheet 2: Table 1

Table 1: Annual Respondent Burden and Cost - NSPS for GHG Emissions for Newly Constructed, Modified, and Reconstructed EGUs (40 CFR Part 60, Subpart TTTT) (Renewal)
					123.94	157.61	62.52
	(A) Hours per Occurrence	(B) Occurrences/ Respondent/ Year	(C) Hours/ Respondent/ Year	(D) Respondents/ Yeara	(E) Technical Hours/Year	(F) Managerial Hours/Year	(G) Clerical Hours/Year	(H) Cost/ Yearc
			(A x B)		(C x D)	(E x .05)	(E x .10)
1. Applications
2. Survey and studies
3. Acquisition, installation, and utilization of technical systems
4. Reporting Requirements
A. Familiarization with regulatory requirements b
Existing Facilities	8	1	8	92	736	37	74	$101,621.36
New Facilities	30	1	30	16	480	24	48	$66,274.80
B. Required activities
Notification of construction	2	1	1	16	16	1	2	$2,209.16
Notification of startup	2	1	1	16	16	1	2	$2,209.16
C. Create information	See 4E
D. Gather existing information	See 4E
E. Prepare/Submit Emissions Summary Report Includes reporting of excess emissions & downtime	4	4	16	92	1,472	74	147	$203,242.72
Reporting Subtotal					3,128			$375,557
5. Recordkeeping requirements	See 4A-E
Recordkeeping Subtotal d					0			$0		8	hrs/response
TOTAL LABOR BURDEN AND COST (rounded)e					3,130			$376,000
TOTAL CAPITAL AND O&M COSTS (rounded)e								$0
GRAND TOTAL (rounded)e								$376,000
Assumptions
a We have assumed there are approximately 60 existing sources and 16 new sources per year anticipated over the next 3 years, resulting in overall average of 92 respondents per year. We have further assumed that there are approximately 106 units (34 combined cycle CT facilities and 72 simple cycle CT units) at 92 facilities.
b Assumes one-time burden of 30 hours for new sources to read and understand rule requirements. Assumes existing respondents will spend 8 hours to refamiliarize with the regulatory requirements each year.
c This ICR uses the following labor rates: Technical $123.94 ($59.02 + 110%); Managerial $157.61 ($75.05 + 110%); and Clerical $62.52 ($29.77 + 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2021, “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. This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours.
d All recordkeeping burden is accounted for in the listed reporting activities.
e 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 GHG Emissions for Newly Constructed, Modified, and Reconstructed EGUs (40 CFR Part 60, Subpart TTTT) (Renewal)
					52.37	70.56	28.34
Burden Item	(A) Hours per Occurrence	(B) Occurrences/ Respondent/	(C) Hours/ Respondent/ Year	(D) Respondents/ Yeara	(F) Technical Hours/ Year	(G) Managerial Hours/ Year	(H) Clerical Hours/Year	(I) Cost/ Yearb
		Year	(A x B)		(C x D)	(E x .05)	(E x .10)
Notification of construction	1	1	1	16	16	1	2	$940
Notification of startup	1	1	1	16	16	1	2	$940
Review Emissions Summary Report Includes reporting of excess emissions & downtime	4	4	16	92	1,472	74	147	$86,454
GRAND TOTAL (rounded)c					1,730			$88,300
Assumptions
a We have assumed there are approximately 60 existing sources and 16 new sources per year anticipated over the next 3 years, resulting in overall average of 92 respondents per year. We have further assumed that there are approximately 106 units (34 combined cycle CT facilities and 72 simple cycle CT units) at 92 facilities.
b This cost is based on the average hourly labor rate as follows: Technical $52.37 (GS-12, Step 1, $32.73 + 60%); Managerial $70.56 (GS-13, Step 5, $44.10 + 60%); and Clerical $28.34(GS-6, Step 3, $17.17 + 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), 2022 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 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

The only type of industry costs associated with the information collection activity in the regulations are labor costs. There are no capital/startup or operation and maintenance costs for this ICR.

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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
Prepare/Submit Emissions Summary Report	92	4	0	368
Notification of construction	16	1	0	16
Notification of startup	16	1	0	16
			Total	400

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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 1	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	16	60	0	0	76
2	16	76	0	0	92
3	16	92	0	0	108
Average	16	76	0	0	92
1 New respondents include sources with constructed, reconstructed and modified affected facilities.