Burden Tables

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Overview

# Respondents
# Responses
Respondent Burden
Agency Burden
Capital & O&M

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Sheet 1: # 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	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	6	0	0	6
2	0	6	0	0	6
3	0	6	0	0	6
Average	0	6	0	0	6
1 New respondents include sources with constructed, reconstructed, and modified affected facilities.

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Sheet 2: # Responses

Total Annual Responses
(A) Information Collection Activity	(B) Number of Respondents	(C) Number of Responses	(D) Number of Existing Respondents That Keep Records But Do Not Submit Reports	(E) Total Annual Responses E=(BxC)+D
Initial notification	0	1	0	0
Notification of compliance status	0	1	0	0
Request for extension of compliance	0	1	0	0
Notification of special compliance requirements	0	1	0	0
Notification of initial performance test	0	1	0	0
Additional notification requirements for sources with CMS	0	1	0	0
Notification of adjustments to time periods	0	1	0	0
Notification of changes to information provided	0	1	0	0
Initial performance test report	0	1	0	0
Inspection and monitoring plan	0	1	0	0
Semiannual report	6	2	0	12
SSM report	0	1	0	0
Excess emissions report	0	1	0	0
Initial report on compliance approach	0	1	0	0
			Total	12		-prev renewal: 12 responses
CMS - Continuous Monitoring System			hrs/response:	1
SSM - Startup, Shutdown, and Malfunction

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Sheet 3: Respondent Burden

Table 1: Annual Respondent Burden and Cost – NESHAP for Publicly Owned Treatment Works (40 CFR Part 63, Subpart VVV) (Renewal)										Source Type	No.
										Existing	6
				Labor Rates:	$103.97	$129.93	$51.79			New (other sectors)	0
Burden item	A	B	C	D	E	F	G	H
	Person-hours per occurrence	Annual occurrences per respondent	Person-hours per respondent per year (AxB)	Respondents per year a	Technical hours per year (CxD)	Management hours per year (Ex0.05)	Clerical hours per year (Ex0.10)	Annual cost ($) b		ERG Notes:
1. Applications	N/A
2. Surveys and studies	N/A
3. Reporting requirements
A. Familiarization with rule requirements c	0.5	1	1	6	3	0.2	0.3	346.94
B. Required activities
Initial notificiation	2	1	2	0	0	0	0	0
Notification of compliance status d	N/A
C. Create information	See 3B
D. Gather existing information	See 3B
E. Write reports
Request for extension of compliance	2	1	2	0	0	0	0	0
Notification of special compliance requirements	2	1	2	0	0	0	0	0
Notification of initial performance test d	N/A
Additional notification requirements for source with CMS	2	1	2	0	0	0	0	0
Notification of adjustments to time periods	2	1	2	0	0	0	0	0
Notification of changes to information provided	2	1	2	0	0	0	0	0
Initial performance test report d	N/A
Inspection and monitoring plan d	N/A
SSM plan d	N/A
Semiannual report	1	2	2	6	12	0.6	1.2	1,387.75
SSM report d	N/A
Excess emissions report	2	1	2	0	0	0	0	0
Initial report on compliance approach	2	1	2	0	0	0	0	0
Reporting Subtotal					17			1,735		Was 14 hrs in prev ICR
4. Recordkeeping
A. Familiarization with rule requirements	See 3A
B. Plan activities	See 3E
C. Implement activities	See 3E
D. Develop record system	See 3E
E. Time to enter information
Records of annual inspections d	N/A
Records of inspections, defects, and repair delays d	N/A
Methods and data used to determine compliance and emissions d	N/A
F. Time to transmit or disclose information	N/A
G. Time to train personnel	N/A
H. Time for audits	N/A
Recordkeeping Subtotal					0			0		Was 0 hrs in prev ICR
TOTAL ANNUAL BURDEN AND COST (ROUNDED) e					17			1,730		Prev renewal: 14 hrs and $1,322. Net increase due to new default assumption that all respondents will spend time on rule reading/familiarization, rather than just new respondents.
TOTAL ANNUAL CAPITAL AND O&M COST (SEE SECTION 6(b)(iii))								0
GRAND TOTAL (LABOR, CAPITAL, AND O&M) e								1,730
CMS - Continuous Monitoring System
N/A - Not Applicable
SSM - Startup, Shutdown, and Malfunction
Assumptions:
a EPA estimates an average of six existing sources will be subject to the standard. We do not expect any new sources will become subject to the rule over the next three years.
b This ICR uses the following labor rates: $103.97 (technical), $129.93 (managerial), and $51.79 (clerical). These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2014, “Table 2. Civilian Workers, by occupational and industry group.” The rates are from column 1, “Total compensation.” They have been increased by 110 percent to account for the benefit packages available to those employed by private industry.
c This burden represents the time existing respondents spend re-familiarizing themselves with rule requirements. For new sources, we assume 4 hours per occurrence is required.
d Only new sources are subject to rule emission limits, control requirements, and related performance testing, plan development, and reporting activities. Since no new sources are expected, these activities are not applicable. These requirements and activities do not apply to existing sources, which demonstrate compliance with the rule by operating treatment and control devices that meet all requirements specified in the appropriate industrial NESHAP(s).
e Totals have been rounded to three significant digits. Figures may not add exactly due to rounding.

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Sheet 4: Agency Burden

Table 2: Average Annual EPA Burden and Cost – NESHAP for Publicly Owned Treatment Works (40 CFR Part 63, Subpart VVV) (Renewal)
				Labor Rates:	$46.67	$62.90	$25.25
Burden item	A	B	C	D	E	F	G	H
	EPA person-hours per occurrence	Annual occurrences per respondent	EPA person-hours per respondent per year (AxB)	Respondents per year a	Technical hours per year (CxD)	Management hours per year (Ex0.05)	Clerical hours per year (Ex0.10)	Annual cost ($) b		ERG Notes:
Initial performance test c	N/A
Repeat initial performance test c	N/A
Report review
Initial notification	2	1	2	0	0	0	0	0
Notification of compliance status c	2	1	2	0	0	0	0	0
Request for extension of compliance	0.5	1	1	0	0	0	0	0
Notification of special compliance requirements	2	1	2	0	0	0	0	0
Notification of initial performance test c	2	1	2	0	0	0	0	0
Additional notification requirements for sources with CMS	2	1	2	0	0	0	0	0
Notification of adjustments to time periods	2	1	2	0	0	0	0	0
Notification of changes to information provided	2	1	2	0	0	0	0	0
Initial performance test report c	N/A
Inspection and monitoring plan c	N/A
Semiannual report	1	2	2	6	12	0.6	1.2	628.08
SSM report c	N/A
Excess emissions report	N/A
Initial report on compliance approach	2	1	2	0	0	0	0	0
TOTAL ANNUAL BURDEN AND COST (ROUNDED) d					14			628		Prev renewal: 14 hrs and $622. Net increase due to updated labor rates
CMS - Continuous Monitoring System
N/A - Not Applicable
SSM - Startup, Malfunction, or Startup
Assumptions:
a EPA estimates an average of six existing sources will be subject to the standard. We do not expect any new sources will become subject to the rule over the next three years.
b This ICR uses the following labor rates: $46.67 (technical), $62.90 (managerial), and $25.25 (clerical). These rates are from the Office of Personnel Management (OPM), 2014 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 Only new sources are subject to rule emission limits, control requirements, and related performance testing, plan development, and reporting activities. Since no new sources are expected, these activities are not applicable. These requirements and activities do not apply to existing sources, which demonstrate compliance with the rule by operating treatment and control devices that meet all requirements specified in the appropriate industrial NESHAP(s).
d Totals have been rounded to three significant digits. Figures may not add exactly due to rounding.

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Sheet 5: Capital & O&M

No Capital/Startup or O&M costs for this ICR.