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 Respondent	22
Number of Respondents	91
Total Estimated Burden Hours	4,650
Total Estimated Costs	$586,000
Annualized Capital O&M	$0
Form Number	Not Applicable

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Sheet 2: Table 1

Table 1: Annual Respondent Burden and Cost – NESHAP for Natural Gas Transmission and Storage (40 CFR Part 63, Subpart HHH) (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. Familiarize with regulatory requirementsc	2	1	2	91	182	9.1	18.2	$26,391.73		Clerical	$65.71
B. Required activities	N/A
C. Create information	N/A
D. Gather existing information	4	1	4	91	364	18.2	36.4	$52,783.46
E. Write Report
i. Notification of construction/ reconstructiond	2	1	2	6	12	0.6	1.2	$1,740.11
ii. Notification of actual startupd	2	1	2	6	12	0.6	1.2	$1,740.11
iii. Notification of date of CMS performance evaluationd	2	1	2	6	12	1	1	$1,740.11
iv. Notification of planned date of performance testd	2	1	2	6	12	0.6	1.2	$1,740.11
v. Notification of compliance status reportd	4	1	4	6	24	1.2	2.4	$3,480.23
vi. Semiannual Periodic Report	4	2	8	91	728	36.4	72.8	$105,566.92
Subtotal for Reporting Requirements					1,548			$195,183
4. Recordkeeping requirements
A. Familiarize with regulatory requirements	See 3A
B. Plan activitiesd	16	1	16	6	96	4.8	9.6	$13,920.91
C. Implement activities	N/A
D. Develop record system
i. Control equipmentd	4	1	4	6	24	1.2	2.4	$3,480.23
E. Time to enter information
i. Control device designd	4	1	4	6	24	1.2	2.4	$3,480.23
ii. Control equipment testingd	1	1	1	6	6	0.3	0.6	$870.06
iii. Control equipment inspection	8	2	16	91	1456	72.8	145.6	$211,133.83
iv. Control equipment monitoring	1	2	2	91	182	9.1	18.2	$26,391.73
v. Control device CMS	1	6	6	91	546	27.3	54.6	$79,175.19
F. Time to train personnel	4	1	4	91	364	18.2	36.4	$52,783.46
G. Perform Audits	N/A
H. Retain records of actual throughput (facilities exempt under 63.1270(f)e	N/A
Subtotal for Recordkeeping Requirements					3,103			$391,236		22	hr/response
Total Labor Burden and Costs (rounded) f					4,650			$586,000
Total Capital and O&M Cost (rounded) f								$0
GRAND TOTAL (rounded) f								$586,000
Assumptions:
a We have assumed that there are approximately 85 respondents subject to the rule, on average over the three year period. It is estimated that 6 additional new or reconstructed sources becoming subject to the rule annually over the next three years, for a total of 91 respondents.
b This ICR uses the following labor rates: $163.17 per hour for Executive, Administrative, and Managerial labor; $130.28 per hour for Technical labor, and $65.71 per hour for Clerical labor. 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 the benefit packages available to those employed by private industry.
c It is estimated that each source will familiarize themselves with the rule requirements each year.
d One-time requirement for the 6 new or reconstructed sources. Performance test reports are submitted with the Notification of Compliance Status and must be developed using EPA’s Electronic Reporting Tool (ERT) and submitted through the EPA’s Compliance and Emissions Data Reporting Interface (CEDRI).
e Respondents are expected to maintain records of actual annual throughput as a standard business practice; therefore, there is no additional burden associated with these records under this rule.
f 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 – NESHAP for Natural Gas Transmission and Storage (40 CFR Part 63, Subpart HHH) (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
Review reports										Labor Rates
a. Initial notification	2	1	2	6	12	0.6	1.2	$733.60		Management	$73.46
b. Preconstruction review application	4	1	4	6	24	1.2	2.4	$1,467		Technical	$54.51
c. Performance test notification	2	1	2	6	12	0.6	1.2	$733.60		Clerical	$29.50
d. Compliance status notification	4	1	4	6	24	1.2	2.4	$1,467.19
e. Semiannual periodic reports	2	2	4	91	364	18.2	36.4	$22,252.41
TOTAL (rounded) c					501			$26,700
Assumptions:
a We assume that an average of 91 respondents (85 existing, 6 new) will be subject to this rule, and that one new source will become subject to the rule each year over the three-year period of the 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%). 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), 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 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.

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Sheet 5: Responses

Total Annual Responses
(A)	(B)	(C)	(D)	(E)
Information Collection Activity	Number of Respondents a	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	6	1	0	6
Notification of actual startup	6	1	0	6
Notification of date of CMS performance evaluation	6	1	0	6
Notification of planned date of performance test	6	1	0	6
Notification of compliance status reporta	6	1	0	6
Semiannual Periodic Report	91	2	0	182
			Total	212
a Performance test reports are submitted with the Notification of Compliance Status and must be developed using EPA’s Electronic Reporting Tool (ERT) and submitted through the EPA’s Compliance and Emissions Data Reporting Interface (CEDRI).

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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 b	Number of Existing Respondents That Are Also New Respondents	Number of Respondents (E=A+B+C-D) c
1	6	79	0	0	85
2	6	85	0	0	91
3	6	91	0	0	97
Average	6	85	0	0	91
a New respondents include sources with constructed, reconstructed, and modified affected facilities.
b Column C does not apply as there are no existing respondents that are required to keep records only on an annual basis since major source determination is a one-time activity to determine rule applicability.
c The previous (currently approved) ICR expires on 2/28/2025. Therefore, Year 1 of this ICR renewal corresponds to March 2025 through February 2026.