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	8
Number of Respondents	41
Total Estimated Burden Hours	850
Total Estimated Costs	$345,000
Annualized Capital O&M	$238,000
Total Annual Responses	103
Form Number	Not Applicable

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Sheet 2: Table 1

Table 1: Annual Respondent Burden and Cost – NSPS for Glass Manufacturing Plants (40 CFR Part 60, Subpart CC) (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. Applications	N/A									Labor Rates
2. Survey and Studies	N/A									Management	$163.17
3. Reporting Requirements										Technical	$130.28
A. Familiarization with rule requirements c	1	1	1	41	41	2.05	4.1	$5,945.39		Clerical	$65.71
B. Required Activities
Initial performance test d	160	1	160	0	0	0	0	$0.00
Repeat of performance test e	160	0.2	32	0	0	0	0	$0.00
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	$0.00
Notification of actual startup f	2	1	2	0	0	0	0	$0.00
Notification of demonstration of CMS	2	1	2	0	0	0	0	$0.00
Notification of physical or operation change g	2	1	2	0	0	0	0	$0.00
Notification of initial performance test	2	1	2	0	0	0	0	$0.00
Performance test report	See 3B
Demonstration of CMS	See 3B
Request for alternative CMS	4	1	4	0	0	0	0	$0.00
Routine maintenance report h	2	1	2	21	42	2.1	4.2	$6,090.40
Semiannual report	8	2	16	41	656	32.8	65.6	$95,126.23
Subtotal for Reporting Requirements					850			$107,162
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
TOTAL LABOR BURDEN AND COST (rounded) i					850			$107,000		850
TOTAL CAPITAL AND O&M COST (rounded) i								$238,000		8	hr/response
GRAND TOTAL (rounded) i								$345,000
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: 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 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 (41 x 50% = 20.5, rounded to 21).
i 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 Glass Manufacturing Plants (40 CFR Part 60, Subpart CC) (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 c	40	1	40	0	0	0	0	$0		Management	$73.46
Repeat performance test										Technical	$54.51
New or modified facility c, d	40	0.2	8	0	0	0	0	$0		Clerical	$29.50
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	$2,568
Review of semiannual reports	4	2	8	41	328	16.4	32.8	$20,052
TOTAL LABOR BURDEN AND COST (rounded) i					426			$22,600
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 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%). 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 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 (41 x 50% = 20.5, rounded to 21).
i 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)
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)
Continuous Opacity Monitors	$21,272	0	$0	$8,225	41	$237,800
Totals (rounded) b			$0			$238,000		$238,000
Assumptions
a Costs have been increased from 2008 to 2022 $ using the CEPCI Equipment Cost Index.
b Totals have been rounded to 3 significant figures. 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	1	0	0
Notification of actual startup	0	1	0	0
Notification of demonstration of CMS	0	1	0	0
Notification of physical or operation change	0	1	0	0
Notification of initial performance test	0	1	0	0
Request for alternative CMS	0	1	0	0
Routine maintenance report	21	1	0	21
Semiannual report	41	2	0	82
			Total	103

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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	41	0	0	41
2	0	41	0	0	41
3	0	41	0	0	41
Average	0	41	0	0	41
a New respondents include sources with constructed and reconstructed affected facilities.