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	43
Number of Respondents	1030
Total Estimated Burden Hours	106,000
Total Estimated Costs	$14,500,000
Annualized Capital O&M	Not Applicable
Total Annual Responses	2478
Form Number	Not Applicable

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Sheet 2: Table 1

Table 1: Annual Respondent Burden and Cost – NSPS for Stationary Combustion Turbines (40 CFR Part 60, Subpart KKKK) (Renewal)										T	M	C
										141.75	172.41	71.36
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 (F=Ex0.05)	(G) Clerical person hours per year (G=Ex0.1)	(H) Total Cost per year, $ b
1. Applications	N/A
2. Surveys and studies	N/A
3. Reporting requirements
A. Familiarization with Regulatory Requirements c	4	1	4	1030	4,121	206.1	412.1	$649,136.79
B. Required activities
Performance test d	12	1	12	280	3,363	168.2	336.3	$529,720.94
Fuel sampling – dual fuel turbines e	0.5	52	26	149	3,874	193.7	387.4	$610,184.88
Fuel sampling – distillate oil only turbines f	0.5	5	2.5	8	20.7	1.03	2.07	$3,259.53
C. Gather existing information	See 3D
D. Write report
Notification of construction/ reconstruction g, h	2	1	2	42	83	4	8	$13,125.54
Notification of actual startup g, h	2	1	2	42	83	4	8	$13,125.54
Notification of performance test d	2	1	2	280	560.5	28.0	56.1	$88,286.82
Notification of demonstration of CEMS i	2	1	2	13	26	1.3	2.6	$4,095.17
Initial notification of compliance g, h	2	1	2	42	83	4	8	$13,125.54
Semiannual Compliance report j, k	8	2	16	1030	16,485	824	1649	$2,596,547.15
Subtotal for Reporting Requirements					33,006			$4,520,608
4. Recordkeeping requirements
A. Familiarization with Regulatory Requirement c	See 3A
B. Train personnel h	40	1	40	42	1,667	83.3333333333333	166.666666666667	$262,510.83
C. Continuous monitoring
Record information k, l	5	12	60	1030	61,820	3,091	6,182	$9,737,051.83
Subtotal for Recordkeeping Requirements					73,010			$9,999,563
TOTAL LABOR BURDEN AND COST (rounded) m					106,000			$14,500,000				106,000
Capital and O&M Cost m								$0
Grand Total m								$14,500,000			43	hr/response
Assumptions:
a We have assumed that there is an annual average of 1030 sources currently subject to the regulations, including 989 existing respondents, and approximately 42 new respondents per year (rounded) who will become subject to the standards.
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.												1030
c We have assumed that it will take 4 hours for respondents to familiarize with regulatory requirements and that all sources will have to familiarize with requlatory requirements.											Updating respondent assumptions (1030 avg was 871 in prev ICR renewal)
d We have assumed that 280 respondents will each take 12 hours to conduct annual stack testing to demonstrate compliance with NOx emission limitation.											was 237	3.68	280
e We have assumed that 149 respondents will each take 0.5 hours 52 times per year to complete fuel sampling for the dual fuel turbines.											was 126	6.91	149
f We have assumed that eight respondents will each take 0.5 hours 5 times per year to complete the fuel sampling for the distillate oil only turbines.											was 8	124	8
g We have assumed that it will take each new respondent 2 hours to write notification report.											was 15
h We have assumed that this is a one-time report for new respondents.
i We have assumed that of the 42 new respondents each year, 13 of these respondents will write reports demonstrating CEMS compliance.
j We have assumed that each of the respondents will take 8 hours twice per year to write the compliance report.
k The average number of respondents is 1030.
l We have assumed that it will take each respondent 5 hours twelve times per year to record information.
m 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 Stationary Combustion Turbines (40 CFR Part 60, Subpart KKKK)(Renewal)											T	M	C
											57.07	76.91	30.88
Activity	(A) EPA person- hours per occurrence	(B) No. of occurrences per plant per year	(C) EPA person- hours per plant per year (C=AxB)	(D) Plants per year a	(E) Technical person-hours per year (E=CxD)	(F) Management person-hours per year (F=Ex0.05)	(G) Clerical person-hours per year (G=Ex0.1)	(H) Cost, $ b
Report Review
1. Notification of construction/reconstruction c	1	1	1	42	42	2	4	$2,666.81
2. Notification of actual startup d	0.5	1	0.5	42	21	1	2	$1,333.41
3. Notification of performance test	2	1	2	280	560	28.0	56.0	$35,841.96
4. Notification of demonstration of CEMS e	2	1	2	13	26	1.3	2.6	$1,664.09
5. Initial notification of compliance	2	1	2	42	83	4	8	$5,333.63
6. Semiannual compliance report f	2	1	2	1030	2061	103	206	$131,889.88
TOTAL ANNUAL BURDEN AND COST (rounded)g					3,210			$179,000
Assumptions:
a We have assumed that there is an annual average of 1030 sources currently subject to the regulations, including 989 existing respondents, and approximately 42 new respondents per year (rounded) who will become subject to the standards.
b This cost is based on the average hourly labor rate as follows: Managerial $76.91 (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), 2024 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 new respondents will take one hour each to review the notification of construction/reconstruction report.
d We have assumed that it will take 0.5 hours for new respondents to review the actual startup report.
e We have assumed that of the 42 new respondents, only 13 of these respondents will review the notification of demonstration of CEMS report.
f We have assumed that it will take 2 hours once per year to review the compliance report.
g 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	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	42	1	0	42
Notification of actual startup	42	1	0	42
Notification of performance test	280	1	0	280
Notification of demonstration of CEMS	13	1	0	13
Initial notification of compliance	42	1	0	42
Semiannual compliance report	1030	2	0	2060
			Total	2478

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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	47	947	0	0	994
	2	47	994	0	0	1041
	3	31	1025	0	0	1056
	Average 2	42	989	0	0	1030
	1 New respondents include sources with constructed, reconstructed and modified affected facilities.
	2 Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.