Burden Calculation Tables

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Overview

Summary
Table 1
Table 2
Capital O&M
Respondents
Responses

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Sheet 1: Summary

ICR Summary Information
Hours Per Response	36
Number of Respondents	85
Total Estimated Burden Hours	12,100
Total Estimated Costs	$6,360,000
Annualized Capital O&M	$4,700,000
Form Number	Not Applicable

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Sheet 2: Table 1

Table 1: Annual Respondent Burden and Cost – NSPS for Kraft Pulp Mills (40 CFR Part 60, Subpart BB) (Renewal)
Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C = A x B)	(D) Respondents per year a	(E) Technical person- hours per year (E = C x D)	(F) Management person hours per year (E x 0.05)	(G) Clerical person hours per year (E x 0.1)	(H) Total Cost Per year b
1. Applications	N/A									Labor Rates
2. Survey and Studies	N/A									Management	$172.41
3. Reporting requirements										Technical	$141.75
A. Familiarization with rule requirements c	1	1	1	85	85	4.3	8.5	$13,388.05		Clerical	$71.36
B. Required activities
Initial performance tests d	374	1	374	0	0	0	0	$0
Repeat of performance tests e	374	0.2	74.8	0	0	0	0	$0
C. Gather existing information	See 3B
D. Write Report
Notification of construction/ reconstruction	2	1	2	0	0	0	0	$0
Notification of performance test	2	1.2	2.4	0	0	0	0	$0
Notification of actual startup	2	1	2	0	0	0	0	$0
Notification of CMS demonstration	2	1	2	0	0	0	0	$0
Notification of physical changes	2	1	2	0	0	0	0	$0
Notification of opacity or visible emissions observations	2	1	2	0	0	0	0	$0
Report of performance test	See 3B
Semiannual report f	8	2	16	85	1,360	68	136	$214,208.84
Excess emissions report g	8	2	16	85	1,360	68	136	$214,208.84
Subtotal for Reporting Requirements					3,226			$441,806
4. Recordkeeping requirements
A. Familiarization with rule requirements	See 3A
B. Plan activities	See 3A
C. Implement Activities	See 3A
D. Develop record system	N/A
E. Time to enter and transmit information
Records of operating parameters h	0.25	365	91.25	85	7,756	388	776	$1,221,659.79
Subtotal for Recordkeeping Requirements					8,920			$1,221,660
Total Labor Burden and Costs (rounded) j					12,100			$1,660,000
Total Capital and O&M Cost (rounded) j								$4,700,000
GRAND TOTAL (rounded) j					12,100			$6,360,000		Responses	340
										Hours/response	36
Assumptions:
a We have assumed an average of 85 existing respondents per year over the next three years. No new respondents are anticipated over the next three years.
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 have assumed that each source will re-familiarize with the requirements each year.
d We have assumed that it will take 374 hours for each new respondent to perform the initial performance test.
e We have assumed that 20 percent of new respondents would repeat performance test due to failure.
f We have assumed that all respondents will each take eight hours to complete the semiannual report.
g We have assumed that each respondent will take eight hours to two times per year to complete the excess emissions report.
h We have assumed that it will take each respondent 15 minutes per day to record operating parameters.
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 Kraft Pulp Mills (40 CFR Part 60, Subpart BB) (Renewal)
Activity	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	EPA person- hours per occurrence	No. of occurrences per plant per year	EPA person- hours per plant per year (C=AxB)	Plants per year a	Technical person- hours per year (E=CxD)	Management person-hours per year (Ex0.05)	Clerical person-hours per year (Ex0.1)	Cost, $ b
Initial performance test (new plant) c	24	1	24	0	0	0	0	$0		Labor Rates
Repeat performance test (new plant) d	24	0.2	4.8	0	0	0	0	$0		Management	$76.91
Review reports (new plant)										Technical	$57.07
Notification of construction	2	1	2	0	0	0	0	$0		Clerical	$30.88
Notification of performance test	2	1.2	2.4	0	0	0	0	$0
Notification of actual startup	0.5	1	0.5	0	0	0	0	$0
Notification of CMS demonstration	0.5	1	0.5	0	0	0	0	$0
Notification of physical/operational changes	0.5	1	0.5	0	0	0	0	$0
Notification of opacity or visible emissions observations	0.5	1	0.5	0	0	0	0	$0
Review test results	8	1.2	9.6	0	0	0	0	$0
Existing plants
Semiannual report and excess emissions report e	4	2	8	85	680	34	68	$43,522.38
TOTAL (rounded) f					782			$43,500
Assumptions:
a We have assumed an average of 85 existing respondents per year over the next three years. No new respondents are anticipated over the next three years.
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 it will take twenty-four hours for the Agency to observe the initial performance test.
d We have assumed that 20 percent of respondents would repeat performance test due to failure and that it will take twenty-four hours for Agency observation of a repeat of the performance test due to failure.
e We have assumed that it will take the Agency four hours to review the semiannual report and the excess emissions report.
f 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, (ExF)		CEPCI Index
Opacity monitor	$61,153	0	$0	$13,148	85	$1,117,580		Year	Index
TRS monitor	$165,114	0	$0	$35,163	85	$2,988,876		2009	521.9
Incinerator temperature monitor	$13,148	0	$0	$7,033	85	$597,775		2023	797.9
Scrubber liquid supply pressure monitor	$535	0	$0	$0	0	$0
Scrubber liquid flow rate monitor	$23,697	0	$0	$0	0	$0
Total			$0			$4,700,000
a Capital/Startup and Annual O&M costs have been updated from 2009 to 2023 using the CEPCI Index.
b Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 5: 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	0	85	0	0	85
2	0	85	0	0	85
3	0	85	0	0	85
Average	0	85	0	0	85
1 New respondents include sources with constructed, reconstructed and modified affected facilities.

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Sheet 6: 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 or modification	0	1	0	0
Notification of actual startup	0	1	0	0
Notification of performance test	0	1.2	0	0
Notification of CMS demonstration	0	1	0	0
Notification of physical or operational changes	0	1	0	0
Notification of opacity or visible emission observations	0	1	0	0
Report of performance test	0	1.2	0	0
Semiannual report	85	2	0	170
Excess emissions report	85	2	0	170
		Total (rounded)		340