| Inputs for Respondent Burden Table |
|
|
|
|
No. of respondents |
|
|
|
Total |
3-yr Ave. |
Applies to: |
| Total number of existing affected plants |
2 |
2 |
|
| No. of new affected plants per year |
0 |
0 |
|
| Total number of affected plants |
2 |
2 |
Read rule; submit Initial Notification; Notification of Compliance Status; train staff; keep records, annual compliance certification |
| No. of small businesses |
0 |
0 |
|
| Reporting |
|
|
|
| Initial Notification |
2 |
1 |
|
| Notification of Compliance Status |
2 |
1 |
|
| Annual Compliance Certification |
2 |
1 |
|
| Annual Report of Exceedences |
1 |
0 |
Assumes 1 facility per year reports an exceedance |
| TOTAL |
|
2 |
|
| Recordkeeping |
|
|
|
| Records of operations |
2 |
2 |
|
| No. of plant transmittals |
|
|
|
| Initial Notification |
2 |
1 |
|
| Notification of Compliance Status |
2 |
1 |
|
| Annual Compliance Certification |
2 |
2 |
|
| Annual Report of Deviations |
0 |
0 |
|
| TOTAL |
|
3 |
|
| Cost of file cabinet |
$0 |
|
|
|
|
|
|
| Labor category -- Respondents |
$/hr |
$/hr (+ Ovhd) |
Description from Reference 1. |
| Technical |
|
$111.48 |
Architecture and Engineering Occupations: 17-0000 |
| Management |
|
$132.04 |
Management Occupations: 11-0000 |
| Clerical |
|
$41.75 |
Office and Administrative Support Occupations: 43-9061 |
| Maintenance |
|
$63.80 |
Installation, Maintenance, Repair |
|
|
|
|
| Labor category -- Agency |
$/hr |
|
Description from Reference 2. |
| Technical |
$46.21 |
|
GS-12, Step 1, $28.88 + 60% |
| Management |
$62.27 |
|
GS-13, Step 5, $38.92 + 60% |
| Clerical |
$25.01 |
|
GS-6, Step 3, $15.63 + 60% |
|
|
|
|
| Ref. 1: May 2010 National Industry-Specific Occupational Employment and Wage Estimates, NAICS 331100-Iron and Steel Mills and Ferroalloy Manufacturing |
| Ref. 2: Office of Personnel Management (OPM) 2010 General Schedule, Salary Table 2010-GS |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| TABLE 1. YEAR 1 ANNUAL RESPONDENT BURDEN AND COST OF REPORTING AND RECORDKEEPING REQUIREMENTS FOR FERROALLOYS PRODUCTION: FERROMANGANESE AND SILICOMANGANESE |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
(A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
(H) |
(I) |
(J) |
(K) |
(L) |
|
Person-hours per occurrence |
Stack testing cost per occurrence |
Other non-labor costs per occurrence |
No. of occurrences per respondent per year |
Person-hours per respondent per year |
Respondents per year |
Technical person-hours per year |
Management person-hours per year |
Clerical person-hours per year |
Total labor costs per year |
Total non-labor costs per year |
Total number of responses per year |
|
|
|
|
|
(AxD) |
|
(ExF) |
(Gx0.05) |
(Gx0.1) |
|
((B+C)xDxF) |
(DxF) |
| 1. Applications |
N/A |
|
|
|
|
|
|
|
|
|
|
|
| 2. Survey and Studies |
N/A |
|
|
|
|
|
|
|
|
|
|
|
| 3. Reporting Requirements |
|
|
|
|
|
|
|
|
|
|
|
|
| A. Read instructions (b) |
20.00 |
|
|
1.0 |
20.0 |
2.0 |
40.0 |
0.4 |
4.0 |
$4,679 |
$0 |
2 |
| B. Required activities |
|
|
|
|
|
|
|
|
|
|
|
|
| a. Initial Compliance test (PM, HCl, Hg, PAH, formaldehyde) - PP FF (c) |
15.00 |
$200,000 |
|
3.0 |
45.0 |
0.0 |
0.0 |
0.0 |
0.0 |
$0 |
$0 |
0 |
| b. Initial Compliance test (PM, HCl, Hg, PAH, formaldehyde) - NP FF/Scrbr (c) |
15.00 |
$52,000 |
|
2.0 |
30.0 |
0.0 |
0.0 |
0.0 |
0.0 |
$0 |
$0 |
0 |
| c. Initial Compliance test (PM) -- NP FF(c) |
20.00 |
$10,000 |
|
4.5 |
90.0 |
0.0 |
0.0 |
0.0 |
0.0 |
$0 |
$0 |
0 |
| d. Initial Method 9 (c) |
4.00 |
$2,000 |
|
1.5 |
6.0 |
0.0 |
0.0 |
0.0 |
0.0 |
$0 |
$0 |
0 |
| e. Manganese ore sampling |
2.00 |
|
$200 |
3.0 |
6.0 |
0.0 |
0.0 |
0.0 |
0.0 |
$0 |
$0 |
0 |
| f. Daily VE check (5 control devices) |
0.25 |
|
|
365.0 |
91.3 |
0.0 |
0.0 |
0.0 |
0.0 |
$0 |
$0 |
0 |
| g. Dailiy VE check (8 control devices) |
0.40 |
|
|
365.0 |
146.0 |
0.0 |
0.0 |
0.0 |
0.0 |
$0 |
$0 |
0 |
| h. Pressure drop/liquid flow rate CPMS-scrubber |
|
|
|
|
|
|
|
|
|
|
|
|
| Initial Capital |
2.00 |
|
$50,000 |
1.0 |
2.0 |
0.0 |
0.0 |
0.0 |
0.0 |
$0 |
$0 |
0 |
| Annual (O&M) |
2.00 |
|
$18,000 |
1.0 |
2.0 |
0.0 |
0.0 |
0.0 |
0.0 |
$0 |
$0 |
0 |
| i. Carbon injection rate CPMS |
|
|
|
|
|
|
|
|
|
|
|
|
| Initial Capital |
2.00 |
|
$20,000 |
1.0 |
2.0 |
0.0 |
0.0 |
0.0 |
0.0 |
$0 |
$0 |
0 |
| Annual (O&M) |
2.00 |
|
$6,200 |
1.0 |
2.0 |
0.0 |
0.0 |
0.0 |
0.0 |
$0 |
$0 |
0 |
| j. Bag Leak Detection System |
|
|
|
|
|
|
|
|
|
|
|
|
| Initial Capital |
4.00 |
|
$265,000 |
0.5 |
2.0 |
0.0 |
0.0 |
0.0 |
0.0 |
$0 |
$0 |
0 |
| Annual (O&M) |
4.00 |
|
$94,000 |
0.5 |
2.0 |
0.0 |
0.0 |
0.0 |
0.0 |
$0 |
$0 |
0 |
| k. Differential pressure monitor |
|
|
|
|
|
|
|
|
|
|
|
|
| Initial Capital |
2.00 |
|
$2,300 |
2.0 |
4.0 |
0.0 |
0.0 |
0.0 |
0.0 |
$0 |
$0 |
0 |
| Annual (O&M) |
2.00 |
|
$230 |
2.0 |
4.0 |
0.0 |
0.0 |
0.0 |
0.0 |
$0 |
$0 |
0 |
| C. Create information |
See 3B |
|
|
|
|
|
|
|
|
|
$0 |
|
| D. Gather existing information |
See 3B |
|
|
|
|
|
|
|
|
|
$0 |
|
| E. Write report |
|
|
|
|
|
|
|
|
|
|
$0 |
|
| a. Initial Notification |
N/A |
|
|
|
|
|
|
|
|
|
|
|
| b. Notification of Compliance Status |
4.00 |
|
|
1.0 |
4.0 |
0.0 |
0.0 |
0.0 |
0.0 |
$0 |
$0 |
0 |
| c. Annual Compliance Certification (d) |
10.00 |
|
|
1.0 |
10.0 |
0.0 |
0.0 |
0.0 |
0.0 |
$0 |
$0 |
0 |
| d. Report of Exceedences (e) |
10.00 |
|
|
1.0 |
10.0 |
0.0 |
0.0 |
0.0 |
0.0 |
$0 |
$0 |
0 |
| e. Develop process fugives ventilation plan |
80.00 |
|
|
1.0 |
80.0 |
2.0 |
160.0 |
1.0 |
16.0 |
$18,637 |
$0 |
2 |
| f. Update fugitive dust control plan |
10.00 |
|
|
1.0 |
10.0 |
2.0 |
20.0 |
1.0 |
2.0 |
$2,445 |
$0 |
2 |
| g. Update baghouse monitoring plan |
10.00 |
|
|
1.0 |
10.0 |
2.0 |
20.0 |
1.0 |
2.0 |
$2,445 |
$0 |
2 |
| h. Develop bagleak detection system SOP |
20.00 |
|
|
1.0 |
20 |
2.0 |
40 |
1 |
4 |
$4,758 |
$0 |
2 |
| i. Affirmative Defense |
30.00 |
|
|
1.0 |
30.0 |
0.0 |
0.0 |
0.0 |
0.0 |
$0 |
$0 |
0 |
| Reporting Subtotal |
|
|
|
762.0 |
628.3 |
10.0 |
280.0 |
4.4 |
28.0 |
$32,964 |
$0 |
10 |
| 4. Recordkeeping Requirements |
|
|
|
|
|
|
|
|
|
|
|
|
| A. Read instructions |
See 3A |
|
|
|
|
|
|
|
|
|
$0 |
0 |
| B. Implement activities |
N/A |
|
|
|
|
|
|
|
|
|
$0 |
0 |
| C. Develop record system |
N/A |
|
|
|
|
|
|
|
|
|
$0 |
0 |
| D. Time to enter information |
|
|
|
|
|
|
|
|
|
|
|
|
| E. Records of all info. required by standards (f) |
1.00 |
|
|
60.0 |
60.0 |
0.0 |
0.0 |
0.0 |
0.0 |
$0 |
$0 |
0 |
| F. Time to train personnel |
20.00 |
|
|
1.0 |
20.0 |
2.0 |
40.0 |
1.0 |
4.0 |
$4,758 |
$0 |
0 |
| G. Time for audits |
N/A |
|
|
|
|
|
|
0.0 |
0.0 |
$0 |
$0 |
0 |
| Recordkeeping Subtotal |
|
|
|
61.0 |
80.0 |
2.0 |
40.0 |
1.0 |
4.0 |
$4,758 |
$0 |
0 |
| TOTAL |
|
|
|
823.0 |
708.3 |
12.0 |
320.0 |
5.4 |
32.0 |
$37,723 |
$0 |
10.0 |
|
|
|
|
|
|
|
Total Hours |
Labor Cost |
Non-Labor |
Total |
|
|
|
|
|
|
Summary of respondent burden |
|
|
357 |
$37,723 |
$0 |
$37,723 |
|
|
|
|
|
|
Initial capital and startup |
|
|
|
|
$0 |
|
|
|
|
|
|
|
Annualized Capital/startup and O&M |
|
|
|
|
$0 |
|
|
|
| N/A = Not Applicable. |
|
|
|
|
|
|
|
|
|
|
|
|
| (a) Costs are based on the following hourly rates: technical at $111.48, management at $132.04, and clerical at $41.75, except the daily VE and Method 22s are $63.80. |
|
|
|
|
|
|
|
|
|
|
|
|
| (b) One-time activity. There are an estimated 2 existing ferroalloys production facilities and no new facilities are expected. |
|
|
|
|
|
|
|
|
|
|
|
|
| (c) Occurs every 5 years, initial tests estimated to occur in Year 2 of ICR. Assume the facilities hire a contractor. Costs based on estimates provided by EPA Emissions Measurement Group. |
|
|
|
|
|
|
|
|
|
|
|
|
| (d) The 2 existing plants would be required to submit an Annual Compliance Certification at the end of Year 2 of the ICR and each year thereafter. |
|
|
|
|
|
|
|
|
|
|
|
|
| (e) Assumes that 2 facilities per year would have to submit a Report of exceedence. |
|
|
|
|
|
|
|
|
|
|
|
|
| (f) Recordkeeping requirements begin in Year 2 of ICR clearance period for all existing plants. |
|
|
|
|
|
|
|
|
|
|
|
|
| (g) Transmittals would include Initial Notifications for 2 plants, Notifications of Compliance Status for 2 plants, Annual Compliance Certifications for |
|
|
|
|
|
|
|
|
|
|
|
|
| 10 plants (combined with exceedence Reports), for an average of (2+2+2)/3 = 2 for each year of the 3-yr ICR clearance period. |
|
|
|
|
|
|
|
|
|
|
|
|
| (i) The total annual number of responses is calculated by summing the product of columns B and D for each of the reports listed in 4B. |
|
|
|
|
|
|
|
|
|
|
|
|
| TABLE 2. YEAR 2 ANNUAL RESPONDENT BURDEN AND COST OF REPORTING AND RECORDKEEPING REQUIREMENTS FOR FERROALLOYS PRODUCTION: FERROMANGANESE AND SILICOMANGANESE |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
(A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
(H) |
(I) |
(J) |
(K) |
(L) |
|
Person-hours per occurrence |
Stack testing cost per occurrence |
Other non-labor costs per occurrence |
No. of occurrences per respondent per year |
Person-hours per respondent per year |
Respondents per year |
Technical person-hours per year |
Management person-hours per year |
Clerical person-hours per year |
Total labor costs per year |
Total non-labor costs per year |
Total number of responses per year |
|
|
|
|
|
(AxD) |
|
(ExF) |
(Gx0.05) |
(Gx0.1) |
|
((B+C)xDxF) |
(DxF) |
| 1. Applications |
N/A |
|
|
|
|
|
|
|
|
|
|
|
| 2. Survey and Studies |
N/A |
|
|
|
|
|
|
|
|
|
|
|
| 3. Reporting Requirements |
|
|
|
|
|
|
|
|
|
|
|
|
| A. Read instructions (b) |
20.00 |
|
|
1.0 |
20.0 |
0.0 |
0.0 |
0.0 |
0.0 |
$0 |
$0 |
0 |
| B. Required activities |
|
|
|
|
|
|
|
|
|
|
|
|
| a. Initial Compliance test (PM, HCl, Hg, PAH, formaldehyde) - PP FF (c) |
15.00 |
$200,000 |
|
3.0 |
45.0 |
1.0 |
45.0 |
0.5 |
4.5 |
$5,270 |
$600,000 |
3 |
| b. Initial Compliance test (PM, HCl, Hg, PAH, formaldehyde) - NP FF/Scrbr (c) |
15.00 |
$52,000 |
|
2.0 |
30.0 |
1.0 |
30.0 |
0.5 |
3.0 |
$3,536 |
$104,000 |
2 |
| c. Initial Compliance test (PM) -- NP FF(c) |
20.00 |
$10,000 |
|
4.5 |
90.0 |
2.0 |
180.0 |
1.0 |
18.0 |
$20,950 |
$90,000 |
9 |
| d. Initial Method 9 (c) |
4.00 |
$2,000 |
|
1.5 |
6.0 |
2.0 |
12.0 |
1.0 |
1.2 |
$1,520 |
$6,000 |
3 |
| e. Manganese ore sampling |
2.00 |
|
$200 |
3.0 |
6.0 |
2.0 |
12.0 |
1.0 |
1.2 |
$1,520 |
$1,200 |
0 |
| f. Daily VE check (5 control devices) |
0.25 |
|
|
365.0 |
91.3 |
1.0 |
91.3 |
0.5 |
9.1 |
$6,269 |
$0 |
0 |
| g. Dailiy VE check (8 control devices) |
0.40 |
|
|
365.0 |
146.0 |
1.0 |
146.0 |
0.5 |
14.6 |
$676 |
$0 |
0 |
| h. Pressure drop/liquid flow rate CPMS-scrubber |
|
|
|
|
|
|
|
|
|
|
|
|
| Initial Capital |
2.00 |
|
$50,000 |
1.0 |
2.0 |
1.0 |
2.0 |
0.5 |
0.2 |
$297 |
$50,000 |
0 |
| Annual (O&M) |
2.0 |
|
$18,000 |
1.0 |
2.0 |
1.0 |
2.0 |
0.5 |
0.2 |
$297 |
$18,000 |
0 |
| i. Carbon injection rate CPMS |
|
|
|
|
|
|
|
|
|
|
|
|
| Initial Capital |
2.0 |
|
$20,000 |
1.0 |
2.0 |
1.0 |
2.0 |
0.5 |
0.2 |
$297 |
$20,000 |
0 |
| Annual (O&M) |
2.0 |
|
$6,200 |
1.0 |
2.0 |
1.0 |
2.0 |
0.5 |
0.2 |
$297 |
$6,200 |
0 |
| j. Bag Leak Detection System |
|
|
|
|
|
|
|
|
|
|
|
|
| Initial Capital |
4.0 |
|
$265,000 |
0.5 |
2.0 |
2.0 |
4.0 |
1.0 |
0.4 |
$595 |
$265,000 |
0 |
| Annual (O&M) |
4.0 |
|
$94,000 |
0.5 |
2.0 |
2.0 |
4.0 |
1.0 |
0.4 |
$595 |
$94,000 |
0 |
| k. Differential pressure monitor |
|
|
|
|
|
|
|
|
|
|
|
|
| Initial Capital |
2.0 |
|
$2,300 |
2.0 |
4.0 |
2.0 |
8.0 |
1.0 |
0.8 |
$1,057 |
$9,200 |
0 |
| Annual (O&M) |
2.0 |
|
$230 |
2.0 |
4.0 |
2.0 |
8.0 |
1.0 |
0.8 |
$1,057 |
$920 |
0 |
| C. Create information |
See 3B |
|
|
|
|
|
|
|
|
|
$0 |
|
| D. Gather existing information |
See 3B |
|
|
|
|
|
|
|
|
|
$0 |
|
| E. Write report |
|
|
|
|
|
|
|
|
|
|
$0 |
|
| a. Initial Notification |
N/A |
|
|
|
|
|
|
|
|
|
|
|
| b. Notification of Compliance Status |
4.0 |
|
|
1.0 |
4.0 |
0.0 |
0.0 |
0.0 |
0.0 |
$0 |
$0 |
0 |
| c. Annual Compliance Certification (d) |
10.0 |
|
|
1.0 |
10.0 |
2.0 |
20.0 |
1.0 |
2.0 |
$2,445 |
$0 |
2 |
| d. Report of Exceedences (e) |
10.0 |
|
|
1.0 |
10.0 |
2.0 |
20.0 |
1.0 |
2.0 |
$2,445 |
$0 |
2 |
| e. Develop process fugives ventilation plan |
80.0 |
|
|
1.0 |
80.0 |
0.0 |
0.0 |
0.0 |
0.0 |
$0 |
$0 |
0 |
| f. Update fugitive dust control plan |
10.0 |
|
|
1.0 |
10.0 |
0.0 |
0.0 |
0.0 |
0.0 |
$0 |
$0 |
0 |
| g. Update baghouse monitoring plan |
10.0 |
|
|
1.0 |
10.0 |
0.0 |
0.0 |
0.0 |
0.0 |
$0 |
$0 |
0 |
| h. Develop bagleak detection system SOP |
20.0 |
|
|
1.0 |
20 |
0.0 |
0 |
0 |
0 |
$0 |
$0 |
0 |
| i. Affirmative Defense |
30.0 |
|
|
1.0 |
30.0 |
0.0 |
0.0 |
0.0 |
0.0 |
$0 |
$0 |
0 |
| Reporting Subtotal |
|
|
|
762.0 |
628.3 |
26.0 |
588.3 |
13 |
58.8 |
$49,124 |
$920,320 |
21 |
| 4. Recordkeeping Requirements |
|
|
|
|
|
|
|
|
|
|
|
|
| A. Read instructions |
See 3A |
|
|
|
|
|
|
|
|
|
$0 |
0 |
| B. Implement activities |
N/A |
|
|
|
|
|
|
|
|
|
$0 |
0 |
| C. Develop record system |
N/A |
|
|
|
|
|
|
|
|
|
$0 |
0 |
| D. Time to enter information |
|
|
|
|
|
|
|
|
|
|
|
|
| E. Records of all info. required by standards (f) |
1.0 |
|
|
60.0 |
60.0 |
0.0 |
0.0 |
0.0 |
0.0 |
$0 |
$0 |
0 |
| F. Time to train personnel |
20.0 |
|
|
1.0 |
20.0 |
2.0 |
40.0 |
1.0 |
4.0 |
$4,758 |
$0 |
0 |
| G. Time for audits |
N/A |
|
|
|
|
|
|
0.0 |
0.0 |
|
$0 |
0 |
| Recordkeeping Subtotal |
|
|
|
61.0 |
80.0 |
2.0 |
40.0 |
1.0 |
4.0 |
$4,758 |
$0 |
0 |
| TOTAL |
|
|
|
823.0 |
708.3 |
28.0 |
628.3 |
14.0 |
62.8 |
$53,882 |
$920,320 |
21.0 |
|
|
|
|
|
|
|
Total Hours |
Labor Cost |
Non-Labor |
Total |
|
|
|
|
|
|
Summary of respondent burden |
|
|
705 |
$53,882 |
$920,320 |
$974,202 |
|
|
|
|
|
|
Initial capital and startup |
|
|
|
|
$344,200 |
|
|
|
|
|
|
|
Annualized Capital/startup and O&M |
|
|
|
|
$920,320 |
|
|
|
| N/A = Not Applicable. |
|
|
|
|
|
|
|
|
|
|
|
|
| (a) Costs are based on the following hourly rates: technical at $111.48, management at $132.04, and clerical at $41.75, except the daily VE and Method 22s are $63.80. |
|
|
|
|
|
|
|
|
|
|
|
|
| (b) One-time activity. There are an estimated 2 existing ferroalloys production facilities and no new facilities are expected. |
|
|
|
|
|
|
|
|
|
|
|
|
| (c) Occurs every 5 years, initial tests estimated to occur in Year 2 of ICR. Assume the facilities hire a contractor. Costs based on estimates provided by EPA Emissions Measurement Group. |
|
|
|
|
|
|
|
|
|
|
|
|
| (d) The 2 existing plants would be required to submit an Annual Compliance Certification at the end of Year 2 of the ICR and each year thereafter. |
|
|
|
|
|
|
|
|
|
|
|
|
| (e) Assumes that 2 facilities per year would have to submit a Report of exceedence. |
|
|
|
|
|
|
|
|
|
|
|
|
| (f) Recordkeeping requirements begin in Year 2 of ICR clearance period for all existing plants. |
|
|
|
|
|
|
|
|
|
|
|
|
| (g) Transmittals would include Initial Notifications for 2 plants, Notifications of Compliance Status for 2 plants, Annual Compliance Certifications for |
|
|
|
|
|
|
|
|
|
|
|
|
| 10 plants (combined with exceedence Reports), for an average of (2+2+2)/3 = 2 for each year of the 3-yr ICR clearance period. |
|
|
|
|
|
|
|
|
|
|
|
|
| (i) The total annual number of responses is calculated by summing the product of columns B and D for each of the reports listed in 4B. |
|
|
|
|
|
|
|
|
|
|
|
|
| TABLE 3. YEAR 3 ANNUAL RESPONDENT BURDEN AND COST OF REPORTING AND RECORDKEEPING REQUIREMENTS FOR FERROALLOYS PRODUCTION: FERROMANGANESE AND SILICOMANGANESE |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
(A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
(H) |
(I) |
(J) |
(K) |
(L) |
|
Person-hours per occurrence |
Stack testing cost per occurrence |
Other non-labor costs per occurrence |
No. of occurrences per respondent per year |
Person-hours per respondent per year |
Respondents per year |
Technical person-hours per year |
Management person-hours per year |
Clerical person-hours per year |
Total labor costs per year |
Total non-labor costs per year |
Total number of responses per year |
|
|
|
|
|
(AxD) |
|
(ExF) |
(Gx0.05) |
(Gx0.1) |
|
((B+C)xDxF) |
(DxF) |
| 1. Applications |
N/A |
|
|
|
|
|
|
|
|
|
|
|
| 2. Survey and Studies |
N/A |
|
|
|
|
|
|
|
|
|
|
|
| 3. Reporting Requirements |
|
|
|
|
|
|
|
|
|
|
|
|
| A. Read instructions (b) |
20.00 |
|
|
1.0 |
20.0 |
0.0 |
0.0 |
0.0 |
0.0 |
$0 |
$0 |
0 |
| B. Required activities |
|
|
|
|
|
|
|
|
|
|
|
|
| a. Initial Compliance test (PM, HCl, Hg, PAH, formaldehyde) - PP FF (c) |
15.00 |
$200,000 |
|
3.0 |
45.0 |
0.0 |
0.0 |
0.0 |
0.0 |
$0 |
$0 |
0 |
| b. Initial Compliance test (PM, HCl, Hg, PAH, formaldehyde) - NP FF/Scrbr (c) |
15.00 |
$52,000 |
|
2.0 |
30.0 |
0.0 |
0.0 |
0.0 |
0.0 |
$0 |
$0 |
0 |
| c. Initial Compliance test (PM) -- NP FF(c) |
20.00 |
$10,000 |
|
4.5 |
90.0 |
0.0 |
0.0 |
0.0 |
0.0 |
$0 |
$0 |
0 |
| d. Initial Method 9 (c) |
4.00 |
$2,000 |
|
1.5 |
6.0 |
0.0 |
0.0 |
0.0 |
0.0 |
$0 |
$0 |
0 |
| e. Manganese ore sampling |
2.00 |
|
$200 |
3.0 |
6.0 |
2.0 |
12.0 |
1.0 |
1.2 |
$1,520 |
$1,200 |
0 |
| f. Daily VE check (5 control devices) |
0.25 |
|
|
365.0 |
91.3 |
1.0 |
91.3 |
0.5 |
9.1 |
$6,269 |
$0 |
0 |
| g. Dailiy VE check (8 control devices) |
0.40 |
|
|
365.0 |
146.0 |
1.0 |
146.0 |
0.5 |
14.6 |
$676 |
$0 |
0 |
| h. Pressure drop/liquid flow rate CPMS-scrubber |
|
|
|
|
|
|
|
|
|
|
|
|
| Initial Capital |
2.00 |
|
$50,000 |
1.0 |
0.0 |
0.0 |
0.0 |
0.0 |
0.0 |
$0 |
$0 |
0 |
| Annual (O&M) |
2.0 |
|
$18,000 |
1.0 |
2.0 |
1.0 |
2.0 |
0.5 |
0.2 |
$297 |
$18,000 |
0 |
| i. Carbon injection rate CPMS |
|
|
|
|
|
|
|
|
|
|
|
|
| Initial Capital |
2.0 |
|
$20,000 |
1.0 |
0.0 |
0.0 |
0.0 |
0.0 |
0.0 |
$0 |
$0 |
0 |
| Annual (O&M) |
2.0 |
|
$6,200 |
1.0 |
2.0 |
1.0 |
2.0 |
0.5 |
0.2 |
$297 |
$6,200 |
0 |
| j. Bag Leak Detection System |
|
|
|
|
|
|
|
|
|
|
|
|
| Initial Capital |
4.0 |
|
$265,000 |
0.5 |
0.0 |
0.0 |
0.0 |
0.0 |
0.0 |
$0 |
$0 |
0 |
| Annual (O&M) |
4.0 |
|
$94,000 |
0.5 |
2.0 |
2.0 |
4.0 |
1.0 |
0.4 |
$595 |
$94,000 |
0 |
| k. Differential pressure monitor |
|
|
|
|
|
|
|
|
|
|
|
|
| Initial Capital |
2.0 |
|
$2,300 |
2.0 |
0.0 |
0.0 |
0.0 |
0.0 |
0.0 |
$0 |
$0 |
0 |
| Annual (O&M) |
2.0 |
|
$230 |
2.0 |
4.0 |
2.0 |
8.0 |
1.0 |
0.8 |
$1,057 |
$920 |
0 |
| C. Create information |
See 3B |
|
|
|
|
|
|
|
|
|
$0 |
|
| D. Gather existing information |
See 3B |
|
|
|
|
|
|
|
|
|
$0 |
|
| E. Write report |
|
|
|
|
|
|
|
|
|
|
$0 |
|
| a. Initial Notification |
N/A |
|
|
|
|
|
|
|
|
|
|
|
| b. Notification of Compliance Status |
4.0 |
|
|
1.0 |
4.0 |
0.0 |
0.0 |
0.0 |
0.0 |
$0 |
$0 |
0 |
| c. Annual Compliance Certification (d) |
10.0 |
|
|
1.0 |
10.0 |
2.0 |
20.0 |
1.0 |
2.0 |
$2,445 |
$0 |
2 |
| d. Report of Exceedences (e) |
10.0 |
|
|
1.0 |
10.0 |
2.0 |
20.0 |
1.0 |
2.0 |
$2,445 |
$0 |
2 |
| e. Develop process fugives ventilation plan |
80.0 |
|
|
1.0 |
80.0 |
0.0 |
0.0 |
0.0 |
0.0 |
$0 |
$0 |
0 |
| f. Update fugitive dust control plan |
10.0 |
|
|
1.0 |
10.0 |
0.0 |
0.0 |
0.0 |
0.0 |
$0 |
$0 |
0 |
| g. Update baghouse monitoring plan |
10.0 |
|
|
1.0 |
10.0 |
0.0 |
0.0 |
0.0 |
0.0 |
$0 |
$0 |
0 |
| h. Develop bagleak detection system SOP |
20.0 |
|
|
1.0 |
20.0 |
0.0 |
0 |
0 |
0 |
$0 |
$0 |
0 |
| i. Affirmative Defense |
30.0 |
|
|
1.0 |
30.0 |
0.0 |
0.0 |
0.0 |
0.0 |
$0 |
$0 |
0 |
| Reporting Subtotal |
|
|
|
762.0 |
618.3 |
14.0 |
305.3 |
7 |
30.5 |
$15,601 |
$120,320 |
4 |
| 4. Recordkeeping Requirements |
|
|
|
|
|
|
|
|
|
|
|
|
| A. Read instructions |
See 3A |
|
|
|
|
|
|
|
|
|
$0 |
0 |
| B. Implement activities |
N/A |
|
|
|
|
|
|
|
|
|
$0 |
0 |
| C. Develop record system |
N/A |
|
|
|
|
|
|
|
|
|
$0 |
0 |
| D. Time to enter information |
|
|
|
|
|
|
|
|
|
|
|
|
| E. Records of all info. required by standards (f) |
1.0 |
|
|
60.0 |
60.0 |
0.0 |
0.0 |
0.0 |
0.0 |
$0 |
$0 |
0 |
| F. Time to train personnel |
20.0 |
|
|
1.0 |
20.0 |
2.0 |
40.0 |
1.0 |
4.0 |
$4,758 |
$0 |
0 |
| G. Time for audits |
N/A |
|
|
|
|
|
|
0.0 |
0.0 |
|
$0 |
0 |
| Recordkeeping Subtotal |
|
|
|
61.0 |
80.0 |
2.0 |
40.0 |
1.0 |
4.0 |
$4,758 |
$0 |
0 |
| TOTAL |
|
|
|
823.0 |
698.3 |
16.0 |
345.3 |
8.0 |
34.5 |
$20,359 |
$120,320 |
4.0 |
|
|
|
|
|
|
|
Total Hours |
Labor Cost |
Non-Labor |
Total |
|
|
|
|
|
|
|
Summary of respondent burden |
|
388 |
$20,359 |
$120,320 |
$140,679 |
|
|
|
|
|
|
|
Initial capital and startup |
|
|
|
$0 |
|
|
|
|
|
|
|
|
Annualized Capital/startup and O&M |
|
|
|
$120,320 |
|
|
|
| N/A = Not Applicable. |
|
|
|
|
|
|
|
|
|
|
|
|
| (a) Costs are based on the following hourly rates: technical at $111.48, management at $132.04, and clerical at $41.75, except the daily VE and Method 22s are $63.80. |
|
|
|
|
|
|
|
|
|
|
|
|
| (b) One-time activity. There are an estimated 2 existing ferroalloys production facilities and no new facilities are expected. |
|
|
|
|
|
|
|
|
|
|
|
|
| (c) Occurs every 5 years, initial tests estimated to occur in Year 2 of ICR. Assume the facilities hire a contractor. Costs based on estimates provided by EPA Emissions Measurement Group. |
|
|
|
|
|
|
|
|
|
|
|
|
| (d) The 2 existing plants would be required to submit an Annual Compliance Certification at the end of Year 2 of the ICR and each year thereafter. |
|
|
|
|
|
|
|
|
|
|
|
|
| (e) Assumes that 2 facilities per year would have to submit a Report of exceedence. |
|
|
|
|
|
|
|
|
|
|
|
|
| (f) Recordkeeping requirements begin in Year 2 of ICR clearance period for all existing plants. |
|
|
|
|
|
|
|
|
|
|
|
|
| (g) Transmittals would include Initial Notifications for 2 plants, Notifications of Compliance Status for 2 plants, Annual Compliance Certifications for |
|
|
|
|
|
|
|
|
|
|
|
|
| 10 plants (combined with exceedence Reports), for an average of (2+2+2)/3 = 2 for each year of the 3-yr ICR clearance period. |
|
|
|
|
|
|
|
|
|
|
|
|
| (i) The total annual number of responses is calculated by summing the product of columns B and D for each of the reports listed in 4B. |
|
|
|
|
|
|
|
|
|
|
|
|
| TABLE 5. YEAR 1 ANNUAL BURDEN AND COST TO THE FEDERAL GOVERNMENT FOR FERROALLOYS PRODUCTION: FERROMANGANESE AND SILICOMANGANESE |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
(A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
(H) |
|
EPA person-hours per occurrence |
No. of occurrences per plant per year |
EPA person-hours per plant per year |
Plants per year |
Technical person-hours per year |
Management person-hours per year |
Clerical person-hours per year |
Cost,$ (a) |
| Activity |
|
|
(C=AxB) |
|
|
|
(Ex0.1) |
|
| Report Review |
|
|
|
|
|
|
|
|
| Initial Notification (b) |
1.0 |
1.0 |
1.0 |
0.7 |
0.7 |
0.0 |
0.1 |
$35 |
| Notification of Compliance Status (c) |
10.0 |
1.0 |
10.0 |
0.7 |
6.7 |
0.3 |
0.7 |
$345 |
| Annual Compliance Certification (d) |
2.0 |
1.0 |
2.0 |
2.0 |
4.0 |
0.2 |
0.4 |
$207 |
| Report of Exceedence (e) |
2.0 |
1.0 |
2.0 |
2.0 |
4.0 |
0.2 |
0.4 |
$207 |
| Review compliance monitoring plans prepared by plants |
10.0 |
0.0 |
0.0 |
2.0 |
0.0 |
0.0 |
0.0 |
$0 |
| TOTAL BURDEN AND COST (SALARY) |
|
|
|
|
15.3 |
0.8 |
1.5 |
$795 |
|
|
|
|
|
|
|
|
|
| (a) Costs are based on the following hourly rates: technical at $46.21, management at $62.27, and clerical at $25.01. |
|
|
|
|
|
|
|
|
| Management person-hours and clerical person-hours are assumed to be 5 percent and 10 percent of technical person-hours, respectively. |
|
|
|
|
|
|
|
|
| (b) The affected 2 plants will submit the initial notification, leading to an average annual burden of 0.7 plants/yr in Year 1. |
|
|
|
|
|
|
|
|
| (c) The affected 2 plants will submit the notification of compliance status, leading to an average annual burden of 0.7 plants/yr in Year 1. |
|
|
|
|
|
|
|
|
| (d) The affected 2 plants will submit an annual compliance certification each year. |
|
|
|
|
|
|
|
|
| (e) Assumes that 2 facilities per year would have to submit an exceedance report per year. |
|
|
|
|
|
|
|
|
| N/A = Not applicable. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Total hours |
18 |
| TABLE 6. YEAR 2 ANNUAL BURDEN AND COST TO THE FEDERAL GOVERNMENT FOR FERROALLOYS PRODUCTION: FERROMANGANESE AND SILICOMANGANESE |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
(A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
(H) |
|
EPA person-hours per occurrence |
No. of occurrences per plant per year |
EPA person-hours per plant per year |
Plants per year |
Technical person-hours per year |
Management person-hours per year |
Clerical person-hours per year |
Cost,$ (a) |
| Activity |
|
|
(C=AxB) |
|
|
|
(Ex0.1) |
|
| Report Review |
|
|
|
|
|
|
|
|
| Initial Notification (b) |
1.0 |
1.0 |
1.0 |
0.7 |
0.7 |
0.0 |
0.1 |
$35 |
| Notification of Compliance Status (c) |
10.0 |
1.0 |
10.0 |
0.7 |
6.7 |
0.3 |
0.7 |
$345 |
| Annual Compliance Certification (d) |
2.0 |
1.0 |
2.0 |
2.0 |
4.0 |
0.2 |
0.4 |
$207 |
| Report of Exceedence (e) |
2.0 |
1.0 |
2.0 |
2.0 |
4.0 |
0.2 |
0.4 |
$207 |
| Review compliance monitoring plans prepared by plants |
10.0 |
4.0 |
40.0 |
2.0 |
80.0 |
4.0 |
8.0 |
$4,146 |
| TOTAL BURDEN AND COST (SALARY) |
|
|
|
|
95.3 |
4.8 |
9.5 |
$4,940 |
|
|
|
|
|
|
|
|
|
| (a) Costs are based on the following hourly rates: technical at $46.21, management at $62.27, and clerical at $25.01. |
|
|
|
|
|
|
|
|
| Management person-hours and clerical person-hours are assumed to be 5 percent and 10 percent of technical person-hours, respectively. |
|
|
|
|
|
|
|
|
| (b) The affected 2 plants will submit the initial notification, leading to an average annual burden of 0.7 plants/yr in Year 1. |
|
|
|
|
|
|
|
|
| (c) The affected 2 plants will submit the notification of compliance status, leading to an average annual burden of 0.7 plants/yr in Year 1. |
|
|
|
|
|
|
|
|
| (d) The affected 2 plants will submit an annual compliance certification each year. |
|
|
|
|
|
|
|
|
| (e) Assumes that 2 facilities per year would have to submit an exceedance report per year. |
|
|
|
|
|
|
|
|
| N/A = Not applicable. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Total hours |
110 |
| TABLE 7. YEAR 3 ANNUAL BURDEN AND COST TO THE FEDERAL GOVERNMENT FOR FERROALLOYS PRODUCTION: FERROMANGANESE AND SILICOMANGANESE |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
(A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
(H) |
|
EPA person-hours per occurrence |
No. of occurrences per plant per year |
EPA person-hours per plant per year |
Plants per year |
Technical person-hours per year |
Management person-hours per year |
Clerical person-hours per year |
Cost,$ (a) |
| Activity |
|
|
(C=AxB) |
|
|
|
(Ex0.1) |
|
| Report Review |
|
|
|
|
|
|
|
|
| Initial Notification (b) |
1.0 |
1.0 |
1.0 |
0.7 |
0.7 |
0.0 |
0.1 |
$35 |
| Notification of Compliance Status (c) |
10.0 |
1.0 |
10.0 |
0.7 |
6.7 |
0.3 |
0.7 |
$345 |
| Annual Compliance Certification (d) |
2.0 |
1.0 |
2.0 |
2.0 |
4.0 |
0.2 |
0.4 |
$207 |
| Report of Exceedence (e) |
2.0 |
1.0 |
2.0 |
2.0 |
4.0 |
0.2 |
0.4 |
$207 |
| Review compliance monitoring plans prepared by plants |
10.0 |
0.0 |
0.0 |
2.0 |
0.0 |
0.0 |
0.0 |
$0 |
| TOTAL BURDEN AND COST (SALARY) |
|
|
|
|
15.3 |
0.8 |
1.5 |
$795 |
|
|
|
|
|
|
|
|
|
| (a) Costs are based on the following hourly rates: technical at $46.21, management at $62.27, and clerical at $25.01. |
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| Management person-hours and clerical person-hours are assumed to be 5 percent and 10 percent of technical person-hours, respectively. |
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|
|
| (b) The affected 2 plants will submit the initial notification, leading to an average annual burden of 0.7 plants/yr in Year 1. |
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|
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| (c) The affected 2 plants will submit the notification of compliance status, leading to an average annual burden of 0.7 plants/yr in Year 1. |
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|
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| (d) The affected 2 plants will submit an annual compliance certification each year. |
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| (e) Assumes that 2 facilities per year would have to submit an exceedance report per year. |
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| N/A = Not applicable. |
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|
|
|
|
|
Total hours |
18 |
| CALCULATIONS NEEDED FOR ROCIS |
|
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|
|
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|
|
|
| Part I: Information Collection Request |
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|
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|
|
|
|
| 14. Annual Cost to Federal Government |
|
|
|
|
|
|
|
|
|
| $794.61 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| Part II: Information Collection Detail |
|
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| 9. Respondents |
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| Total number: |
2 |
|
|
|
|
|
|
|
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| Small entity number: |
0 |
|
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|
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|
|
|
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| 10. Frequency |
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| Calculated Annual Frequency: |
|
|
|
1.0 |
|
|
|
|
|
| Calculated Annual Number of Responses: |
|
|
|
12 |
|
|
|
|
|
|
|
|
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|
|
|
|
|
| 11. Hour and Cost Burden |
|
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|
Hours per Response |
% of responses |
Avg. hours per response |
Total Annual Hour Burden |
Cost per Response (Capital/Startup and O&M Costs) |
Total Annual Cost Burden (Capital/Startup and O&M Costs) |
Comments |
|
|
| Reporting |
1.85 |
0.32 |
12.88 |
154.69 |
$28,906.67 |
$346,880 |
Hours per response based on year 1. Used 3-yr avg. burden to estimate total annual hour burden. |
|
|
| Recordkeeping |
3.93 |
0.68 |
27.37 |
328.72 |
$0.00 |
$0.00 |
Hours per response based on year 1. Used 3-yr avg. burden to estimate total annual hour burden. |
|
|
| Third Party Disclosure |
|
|
|
|
$0 |
|
|
|
|
| Totals |
5.78 |
|
40.25 |
483.42 |
$28,907 |
$346,880 |
|
|
|
|
|
|
|
|
|
|
|
|
|
| 12. Allocate the change in Burden |
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|
Total Requested |
|
|
Change Due to New Statute |
Change Due to Agency Decision |
Due to Agency Estimate |
Change due to Violation |
Currently Approved |
Comments |
| Annual Responses |
12 |
|
|
|
|
|
|
|
|
| Annual Hour Burden |
483 |
|
|
|
|
|
|
|
|
| Annual Cost Burden (Capital/Startup and O&M Costs) |
$346,880 |
|
|
|
|
|
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|
|