Burden 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	132
Number of Respondents	4
Total Estimated Burden Hours	1,410
Total Estimated Costs	$969,000
Annualized Capital O&M	$776,000
Form Number	Not Applicable

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Sheet 2: Table 1

Table 1: Annual Respondent Burden and Cost – NESHAP for Manufacturing of Nutritional Yeast (40 CFR Part 63, Subpart CCCC) (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. Reporting requirements										Labor Rates
A. Familiarization with regulatory requirements c	15	1	15	4	60	3	6	$9,450.39		Management	$172.41
B. Required Activities										Technical	$141.75
i. VOC CEMS d										Clerical	$71.36
a. Capital Cost	0	1	0	0	0	0	0	$0.00
b. Annualized Cost e	0	1	0	4	0	0	0	$0.00
ii. Performance evaluation f	8	1	8	1.33	10.6	0.5	1.1	$1,675.87
a. CEMS RATA g	0	6.5	0	1.33	0	0	0	$0.00
3. Brew Ethanol Correlation	10	3	30	0	0	0	0	$0.00
C. Create Information	See 3B
D. Gather Information	See 3E
E. Report Preparation
i. Develop Performance Evaluation Plan	15	1	15	0	0	0	0	$0.00
ii. Notification of Performance Evaluation	2	1	2	1.33	2.7	0.1	0.3	$418.97
iii. Performance Evaluation Report	2	1	2	1.33	2.7	0.1	0.3	$418.97
iv. Notification of Performance Test	2	1	2	0	0	0	0	$0.00
v. Notification of Compliance Status	4	1	4	0	0	0	0	$0.00
vi. Semiannual Compliance Report	4	2	8	4	32	1.6	3.2	$5,040.21
Subtotal for Reporting Requirements					124			$17,004
2. Recordkeeping Requirements
A. Read Instructions	See 3A
B. Implement Activities	NA
C. Develop Record System	NA
i. Compliance Calculation Tracking	20	1	20	0	0	0	0.0	$0.00
D. Record information
i. Performance Evaluations	2	1	2	1.33	2.7	0.1	0.3	$418.97
ii. CEMS Measurements	0.5	350	175	4	700	35	70.0	$110,254.55
iii. Compliance Calculation	4	12	48	4	192	9.6	19.2	$30,241.25
iv. CEMS Calibration and Maintenance	See 3B
v. Store, File, and Maintain Records	12	1	12	4	48	2.4	4.8	$7,560.31
vi. Retrieve Records/Reports	20	1	20	4	80	4	8.0	$12,600.52
E. Personnel Training
i. Acquisition, Installation, & Training	20	1	20	4	80	4	8.0	$12,600.52
ii. CEMS Inspection and Monitoring	4	1	4	4	16	0.8	1.6	$2,520.10
F. Time for Audits			0	4	0	0	0.0	$0.00
Subtotal for Recordkeeping Requirements					1,286			$176,196		132	hr/response
Total Labor Burden and Costs (rounded) h					1,410			$193,000
Total Capital and O&M Cost (rounded) h								$776,000
GRAND TOTAL (rounded) h								$969,000
Assumptions:
a We assume that an average of 4 respondents will be subject to this rule, and that no new source will become subject to the rule each year over the three-year period of the ICR.
b This ICR uses the following labor rates: Managerial $172.41 ($82.10 + 110%); Technical $141.75 ($67.50 + 110%); and Clerical $71.36 ($33.98 + 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, December 2023, “Table 2. Civilian Workers, by occupational and industry group.” The rates are from column 1, “Total compensation.” The rates are 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 assume that all of the respondents will have to familiarize with the regulatory requirements each year.
d All facilities must use VOC CEMS.
e Annualized cost equals the average of all facility annualized costs (based on number of fermenters). Includes operation, maintenance, and repairs of CEMS.
f Labor hours to conduct performance evaluation of CEMS. Assumes 4 respondents will complete over 12 quarters or 3 years for average of 1.33/year.
g Line item for annual non-labor cost to conduct RATA. Number of occurrences per respondent equals the average number of CEMS (i.e., fermenters) per facility. Assumes 4 sources will complete over 12 quarters or 3 years for average of 1.33/year.
h 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 Manufacturing of Nutritional Yeast (40 CFR Part 63, Subpart CCCC) (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
Report review										Labor Rates
Review Notification of Performance Evaluation	0.5	1	0.5	1.33	0.7	0.0	0.1	$42.56		Managerial	$76.92
Review Notification of Performance Test	0.5	1	0.5	0	0.0	0.0	0.0	$0.00		Technical	$57.07
Review Performance Evaluation Report	5	1	5	1.33	6.7	0.3	0.7	$425.63		Clerical	$30.88
Review Performance Test Report	5	1	5	0	0	0	0	$0.00
Review Semiannual Compliance Report	10	2	20	4	80	4	8	$5,120.32
Prepare annual summary report	10	1	10	1	10	0.5	1	$640.04
TOTAL (rounded) c					112			$5,590
Assumptions:
a We assume that an average of 4 respondents will be subject to this rule, and that no new sources 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 $76.92 (GS-13, Step 5, $48.07 + 60%); Technical $57.07 (GS-12, Step 1, $35.67 + 60%); and Clerical $30.88 (GS-6, Step 3, $19.30+ 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

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	Number of New Respondents	Total Capital/Startup Cost, (B X C)	Annual O&M Costs for One Respondent d	Number of Respondents with O&M	Total O&M, (E X F)
VOC CEMsa	$86,770	0	$0	$186,860	4	$747,440
CEMS RATAb	$0	0	$0	$21,216	1.33	$28,217
Brew Ethanol Correlationc	$0	0	$0	$19,500	0	$0
Totals (rounded) e			$0			$776,000		$776,000
a Assumes all facilities have installed CEMS to comply with the rule. Annual costs include operation, maintenance, and repair of CEMS.
b Assumes an annual O&M cost of $3,624 to conduct RATA per CEMS and an average of 6.5 CEMs per facility. Assumes 4 respondents will complete over 12 quarters or 3 years for average of 1.33 respondents/year.
c Assumes no facilities will conduct brew ethanol correlation.
d Annualized capital costs were calculated based on 2015 dollars using an equipment life of 10 years and a 7 percent discount rate.
e 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 a	Number of Responses	Number of Existing Respondents That Keep Records But Do Not Submit Reports	Total Annual Responses E=(BxC)+D
Notification of Performance Evaluation	1.33	1	0	1.33
Performance Evaluation Report	1.33	1	0	1.33
Notification of Performance Test	0	1	0	0
Performance Test Report	0	1	0	0
Notification of Compliance Status	0	1	0	0
Semiannual Report	4	2	0	8
			Total	11

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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	4	0	0	4
2	0	4	0	0	4
3	0	4	0	0	4
Average	0	4	0	0	4
a New respondents include sources with constructed and reconstructed affected facilities.