Table 1: Annual Respondent Burden and Cost – NESHAP for Secondary Aluminum Production (40 CFR Part 63, Subpart
RRR) (Renewal) |
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103.97 |
129.93 |
51.79 |
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| Burden item |
(A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
(H) |
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| 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) |
Total Cost
Per year b |
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| 1. Applications |
N/A |
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| 2. Surveys and studies |
N/A |
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| 3. Acquisition, installation, and utilization of technology and systems c |
54 |
1 |
54 |
DWang:
Changed from 70 to 0
0 |
0 |
0 |
0 |
$0.00 |
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| 4. Reporting requirements |
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| a. Read and understand rule requirements d |
DWang:
Changed from 0.13 to 1
1 |
1 |
1 |
DWang:
Changed from 70 to 161
161 |
161 |
8.05 |
16.1 |
$18,618.93 |
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| b. Required activities |
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| Initial performance test e, f |
24 |
1 |
24 |
0 |
0 |
0 |
0 |
$0.00 |
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| Repeat performance test e, f |
24 |
0.2 |
4.8 |
0 |
0 |
0 |
0 |
$0.00 |
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| Operating, maintenance and monitoring plan e, f |
32 |
1 |
32 |
DWang:
Changed from 70 to 0
0 |
0 |
0 |
0 |
$0.00 |
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| Startup, shutdown, malfunction (SSM) plan g |
N/A |
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| c. Create information |
See 4B |
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| d. Gather existing information |
See 4B |
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| e. Write report |
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| Notification of applicability e, f |
2 |
1 |
2 |
DWang:
Changed from 70 to 0
0 |
0 |
0 |
0 |
$0.00 |
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| Notification of construction/reconstruction |
N/A |
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| Notification/report of actual startup |
N/A |
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| Notification of special compliance requirements |
N/A |
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| Notification of performance test e |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0.00 |
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| Notification of compliance status e |
4 |
1 |
4 |
DWang:
Changed from 81 to 53
53 |
212 |
10.6 |
21.2 |
$24,516.85 |
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| Waiver application h |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0.00 |
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| Report of performance test |
See 4B |
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| Semiannual reports i |
8 |
2 |
16 |
DWang:
Changed from 1764 to 161
161 |
2,576 |
128.8 |
257.6 |
$297,902.81 |
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DWang:
Added from 2015 amendment
Changing furnace classification j |
2 |
1 |
2 |
50 |
100 |
5 |
10 |
$11,564.55 |
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| SSM report g |
N/A |
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| Subtotal for Reporting Requirements |
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3,506 |
$352,603 |
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| 5. Recordkeeping requirements |
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| a. Read and understand rule requirements |
4 |
1 |
4 |
DWang:
Changed from 81 to 53
53 |
212 |
10.6 |
21.2 |
$24,516.85 |
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| b. Plan activities |
See 4E |
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| c. Implement activities |
See 4B |
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| Verify lime injection rate |
0.1 |
36 |
3.6 |
161 |
579.6 |
28.98 |
57.96 |
$67,028.13 |
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DWang:
Added from 2015 amendment
Changing furnace classification j |
2 |
1 |
2 |
50 |
100 |
5 |
10 |
$11,564.55 |
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| d. Develop record system |
N/A |
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| e. Time to enter/transmit information |
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| Records of all information required by the standards |
N/A |
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| Major sources k |
1.5 |
52 |
78 |
DWang:
Changed from 81 to 53
53 |
4,134 |
206.7 |
413.4 |
$478,078.50 |
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DWang:
Changed from "Sweat furnaces" to "area sources"
Area sources l |
0.5 |
52 |
26 |
DWang:
Changed from 1683 to 108
108 |
2,808 |
140.4 |
280.8 |
$324,732.56 |
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| f. Time to train personnel m |
4 |
1 |
4 |
DWang:
Changed from 70 to 0
0 |
0 |
0 |
0 |
$0.00 |
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| g. Time to adjust existing ways to comply with previous applicable requirements |
N/A |
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| h. Time to disclose information |
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| New sources n |
0.25 |
2 |
0.5 |
DWang:
Changed from 70 to 0
0 |
0 |
0 |
0 |
$0.00 |
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| All sources o |
0.25 |
2 |
0.5 |
DWang:
Changed from 1764 to 161
161 |
81 |
4.03 |
8.05 |
$9,309.46 |
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DWang:
Added from 2015 amendment
Sources that changed furnace classification j |
1 |
1 |
1 |
50 |
50 |
2.5 |
5 |
$5,782.28 |
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| i. Time for audits |
N/A |
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| Subtotal for Recordkeeping Requirements |
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9,101 |
$915,230 |
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| TOTAL LABOR BURDEN AND COST (rounded)p |
12,600 |
$1,270,000 |
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| Total Capital/O&M Costs (rounded)p |
$4,110,000 |
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| Grand Total (Labor and Capital/O&M Costs)(rounded)p |
$5,380,000 |
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| Assumptions: |
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30 |
hr/response |
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DWang:
The amendment ICR does not say if there will be any new area sources, so I am assuming that there willl not be any.
a We have assumed that the average number of respondents that will be subject to this rule will be 161, of which 53 are major sources. There will be no additional new major or area sources over the three-year period of this ICR. |
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| 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. |
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DWang:
Changed from "new sweat furnaces" to "new respondents".
c We have assumed that it will take each new respondent 54 hours to complete the task. This burden cost is associated with the monitoring of all control equipment ensuring that respondents of new respondents meet the required specifications of this subpart. |
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DWang:
Changing from 0.13 to 1 hour and changed "read instructions" to "read and understand the rule requirements. "
d We have assumed that it will take each respondent one hour to read and understand the rule requirements. |
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DWang:
Changed "sweat furnace" to "area sources"
e We have assumed that all existing sources are in compliance with the initial rule requirements. It is further assumed that new area sources will comply by meeting the equipment specifications rather than by conducting performance tests. Respondents that are major sources are required to demonstrate initial compliance with the applicable emission limit, equipment, work practice, or operational standard for affected source or emission unit and report results in the notification of compliance status report. |
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DWang:
Changed "sweat furnace" to "area sources"
f Since we have assumed that there will be no new sources over the next three-year period of this ICR, there will be no new sources conducting initial performance tests. We have determined that respondents of new area sources will not be required to conduct emissions testing to show compliance with the emission limit, since it was determined that sweat furnaces sold in the United States now have an afterburner installed and meet the design residence time of 0.8 seconds or greater and an operating temperature of 1600 oF or greater. All new respondents are required to submit for approval an operation, maintenance and monitoring plan for affected sources. |
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| g This burden item is no longer required as a result of the 2015 final amendment. |
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| h It is assumed that there will be no new sources requiring a waiver from the performance test requirements. |
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| i It is assumed that each respondent will take 8 hours to write semiannual report of excess emissions or no excess emissions. |
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| j An estimated 50 facilities would change furnace classifications once per year. |
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| k It is assumed that it will take 1.5 hours for major source respondents to enter and transmit records. |
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DWang:
Changed "sweat furnace" to "area sources"
l It is assumed that it will take 0.5 hours for existing area source respondents to enter and transmit records. |
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DWang:
Changed from "new sweat furance employees" to "new employees"
m We have assumed that it will take 4 hours to train new employees. |
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DWang:
Changed from "new sweat furnace respondent" to "new respondent"
n We have assumed that it will take 0.25 hours to each new respondent to disclose information. |
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| o We have assumed that it will take 0.25 hours for each respondent to disclose information. |
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| p Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
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Table 2: Average Annual EPA Burden and Cost - NESHAP for Secondary Aluminum Production (40 CFR Part 63, Subpart
RRR) (Renewal)
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46.67 |
62.9 |
25.25 |
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| 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 tests |
40 |
1.4 |
56 |
0 |
0 |
0 |
0 |
$0 |
| Report performance test including retesting c |
48 |
1 |
48 |
0 |
0 |
0 |
0 |
$0 |
| Notification of applicability |
0.5 |
1 |
0.5 |
DWang:
Changed from 70 to 0
0 |
0 |
0 |
0 |
$0 |
| Notification of construction/reconstruction |
N/A |
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|
|
|
|
|
| Notification of actual startup |
N/A |
|
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|
|
|
|
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| Notification of special compliance requirements |
N/A |
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|
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| Notification of performance test |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
| Notification of compliance status d |
2 |
1 |
2 |
DWang:
Changed from 70 to 0
0 |
0 |
0 |
0 |
$0 |
| Report of performance test c |
40 |
1 |
40 |
0 |
0 |
0 |
0 |
$0 |
| Repeat of performance test report c |
40 |
1 |
40 |
0 |
0 |
0 |
0 |
$0 |
| Semiannual reports e |
4 |
2 |
8 |
DWang:
Changed from 1764 to 161
161 |
1288 |
64.4 |
128.8 |
$67,413.92 |
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DWang:
Changed to remove burden
Startup, shutdown, malfunction report f |
N/A |
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| Review performance test reports and reports from facilities changing furnace classification g |
4 |
1 |
4 |
59 |
236 |
11.8 |
23.6 |
$12,352.24 |
| TOTAL ANNUAL BURDEN AND COST (rounded)h |
1,750 |
$79,800 |
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| Assumptions: |
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DWang:
The amendment ICR does not say if there will be any new area sources, so I am assuming that there willl not be any.
a We have assumed that the average number of respondents that will be subject to this rule will be 161, of which 53 are major sources. There will be no additional new major or area sources over the three-year period of this ICR. |
| b This cost is based on the following hourly labor rates: $62.90 for Managerial (GS-13, Step 5, $39.31 + 60%), $46.67 for Technical (GS-12, Step 1, $29.17 + 60%) and $25.25 Clerical (GS-6, Step 3, $15.78 + 60%). 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% to account for the benefit packages available to government employees. |
| c We have assumed that all existing respondent are in compliance with the initial rule requirements. It is further assumed that new sweat furnaces will comply by meeting the equipment specification than by conducting performance test. |
| d We have assumed that it will take 2 hours for each respondent to complete notification of compliance status. |
| e We have assumed that each existing respondent will take 4 hours two times per year to complete the semiannual reports. |
| f This burden item is no longer required as a result of the 2015 final amendment. |
| h Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |