Burden Tables

2040.06_burden estimates.xlsx

NESHAP for Refractory Products Manufacturing (40 CFR Part 63, Subpart SSSSS) (Renewal)

Burden Tables

OMB: 2060-0515

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Overview

Industry
Agency


Sheet 1: Industry

Table 1: Annual Respondent Burden and Cost – NESHAP for Refractory Products Manufacturing (40 CFR Part 63, Subpart SSSSS) (Renewal)







































103.97 129.93 51.79



Burden item (A) (B) (C) (D) (E) (F) (G) (H)



Person-hours per occurrence No. of occurrences per respondent per year Person-hours per respondent per year (C=AxB) Respondents 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


1. Applications N/A









2. Survey and Studies N/A









3. Reporting Requirements










A. Familiarize with rule requirement 0.5 1 0.5 8 4 0.2 0.4 $462.58


B. Required activities










Startup, shutdown, malfunction plan 32 1 32 0 0 0 0 $0


Operation, maintenance, monitoring plan 32 1 32 0 0 0 0 $0


C. Create information See 3B









D. Gather existing information See 3B









E. Write report










Notification of applicability 2 1 2 0 0 0 0 $0


Notification of construction/ reconstruction 2 1 2 0 0 0 0 $0


Notification of anticipated startup 2 1 2 0 0 0 0 $0


Notification of actual startup 2 1 2
0 0 0 $0


Notification of performance test 2 1 2 0 0 0 0 $0


Notification of compliance status 16 1 16 0 0 0 0 $0


Notification of intent to use alternative fuel c 2 1 2 3 6 0.3 0.6 $693.87


Report of deviations d 16 1 16 1 16 0.8 1.6 $1,850.33


Report of no deviations e 8 2 16 7 112 5.6 11.2 $12,952.30


Startup, shutdown, malfunction report f 8 1 8 1 8 0.4 0.8 $925.16


Report of alternative fuel use g 4 1 4 3 12 0.6 1.2 $1,387.75


Subtotal for Reporting Requirements



182 $18,271.99


4. Recordkeeping Requirements










A. Familiarize with rule requirement h 4 1 4 8 32 1.6 3.2 $3,700.66


B. Plan activities See 4E









C. Implement activities See 4E









D. Develop record system See 4E








E. Time to enter information










Records of all information required by standards i 0.25 52 13 8 104 5.2 10.4 $12,027.13


F. Time to train personnel 20 1 20 0 0 0 0 $0


G. Time to adjust existing ways to comply with previously applicable requirements N/A









H. Time to transmit or disclose information j 0.25 2 0.5 8 4 0.2 0.4 $463


I. Time for audits N/A









Subtotal for Recordkeeping Requirements



161 $16,190.37


TOTAL ANNUAL BURDEN AND COSTS: k



343 $34,000


Capital and O&M Cost (see Section 6(b)(iii)): k






$3,040


TOTAL COST: k






$37,000
16 hr/resp
























Assumptions:










a We have assumed that the average number of respondents that will be subject to the rule will be eight. There will be no additional new source per year that will become subject to the rule over the three-year period of this ICR.










b This ICR uses the following labor rates: $129.93 per hour for Executive, Administrative, and Managerial labor; $103.97 per hour for Technical labor, and $51.79 per hour for Clerical labor. 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.” The rates have been increased by 110% to account for the benefit packages available to those employed by private industry.










c We have assumed that three respondent will use alternative fuel once per year and will have to submit notification of intent to use alternative fuel.










d We have assumed that one respondent will report deviation once a year.










e We have assumed that seven respondents will report no deviation on a semiannual basis.










f It is assumed that one respondents will have a startup, shutdown, malfunction occur.










g We have assumed that three respondents will report on alternative fuel usage once a year.










h We have assumed that it will take 4 hours for each respondent to read and familiarize with rule requirements.










i We have assumed that information will be recorded once per week for 52 weeks per year.










j We have assumed that it will take 0.25 hours for information to be transmitted or disclosed.










k Totals have been rounded to 3 significant values. Figures may not add exactly due to rounding.











Sheet 2: Agency

Table 2: Average Annual EPA Burden and Cost – NESHAP for Refractory Products Manufacturing (40 CFR Part 63, Subpart SSSSS) (Renewal)





















46.67 62.9 25.25
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
Attend initial performance test 40 1 40 0 0 0 0 $0
Attend repeat performance test







Retesting preparation 8 1 8 0 0 0 0 $0
Retesting 40 1 40 0 0 0 0 $0
Report Review







Notification of applicability 2 1 2 0 0 0 0 $0
Notification of construction/reconstruction 2 1 2 0 0 0 0 $0
Notification of anticipated startup 2 1 2 0 0 0 0 $0
Notification of actual startup 2 1 2 0 0 0 0 $0
Notification of initial performance test 2 1 2 0 0 0 0 $0
Notification of compliance status 2 1 2 0 0 0 0 $0
Notification of intent to use alternative fuel c 2 1 2 3 6 0.3 0.6 $314.04
Repeat performance test report 40 1 40 0 0 0 0 $0
Semiannual compliance reports







Deviation d 16 1 16 1 16 0.8 1.6 $837.44
No Deviation e 8 2 16 7 112 5.6 11.2 $5,862.08
Startup, shutdown, malfunction report f 16 1 16 1 16 0.8 1.6 $837.44
Notification of alternative fuel use g 2 1 2 3 6 0.3 0.6 $314.04
TOTAL ANNUAL BURDEN AND COST h



179 $8,170




































Assumptions:







a We have assumed that the average number of respondents that will be subject to the rule will be eight. There will be no additional new source per year that will become subject to the rule over the three-year period of this ICR.







b This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: Managerial rate of $62.90 (GS-13, Step 5, $39.31 x 1.6), Technical rate of $46.67 (GS-12, Step 1, $29.17 x 1.6), and Clerical rate of $25.25 (GS-6, Step 3, $15.78 x 1.6). These rates are from the Office of Personnel Management (OPM) “2015 General Schedule” which excludes locality rates of pay.







c We have assumed that three respondent will use alternative fuel once per year and will have to submit notification of intent to use alternative fuel.







d We have assumed that one respondent will report deviation once a year.







e We have assumed that seven respondents will report no deviation on a semiannual basis.







f It is assumed that one respondents will have a startup, shutdown, malfunction occur.







g We have assumed that three respondents will report on alternative fuel usage once a year.







h Totals have been rounded to 3 significant values. Figures may not add exactly due to rounding.







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