Calculation Tables for ICR 2274.05

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Overview

Table 1
Table 2

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Sheet 1: Table 1

Table 1: Annual Respondent Burden and Cost – NESHAP for Clay Ceramics Manufacturing, Glass Manufacturing, and Secondary Nonferrous Metals Processing (40 CFR Part 63, Subparts RRRRRR, SSSSSS, and TTTTTT) (Renewal)
					106.45	138.43	52.77
Burden Item	(A) Respondent Hours per Occurrence	(B) Number of Occurrences per Respondent per Year	(C) Hours per Respondent per Year (C=AxB)	(D) Number of Respondents per Year	(E) Technical Hours per Year (E=CxD)	(F) Management Hours per Year (F=Ex0.05)	(G) Clerical Hours per Year (G=Ex0.1)	(H) Total Labor Costs per Year a
1. Applications	N/A
2. Surveys and Studies	N/A
3. Acquisition, installation, and utilization of technology and systems	N/A
4. Reporting Requirements
A. Familiarize with regulatory requirements b	2	1	2	21	42	2.1	4.2	$4,983.24
B. Required activities
Initial notification of applicability c	2	1	2	0	0	0	0	$0
Notification of compliance status d	4	1	4	0	0	0	0	$0
C. Create information	See 4B
D. Gather existing information	See 4B
E. Write report	See 4B
Subtotal for Reporting Requirements					48			$4,983
5. Recordkeeping Requirements
A. Familiarize with regulatory requirements e	See 4A
B. Plan activities	See 5E
C. Implement activities	See 5E
D. Record data f, i	0.1	1,095	109.5	14	1,533	76.65	153.3	$181,888.15
E. Time to transmit or disclose information g, i	0.25	3.3	0.83	0	0	0	0	$0
F. Time to train personnel h, i	12	1	12	0	0	0	0	$0
G. Time for audits i	N/A
Subtotal for Recordkeeping Requirements					1,763			$181,888
TOTAL LABOR BURDEN AND COST (rounded) j					1,810			$187,000
TOTAL CAPITAL AND O&M COST (rounded) j								$9,850		129	hr/response
GRAND TOTAL (rounded) j								$197,000
Assumptions:
a This ICR uses the following labor rates: $138.43 for managerial labor, $106.45 for technical labor, and $52.77 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2015, “Table 2. Civilian Workers, by Occupational and Industry group.” The rates are from column 1, “Total Compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry.
b There are an estimated 21 existing glass manufacturing facilities, 51 existing clay manufacturing facilities, and 10 existing secondary nonferrous metals processing facilities that use HAP metals. We asssume all existing respondent will have to re-famliarize with regulatory requirements each year. No new facilities are expected in any of the industries.
c After full implementation, existing facilities are no longer required to submit an Initial Notification.
d After full implementation, existing facilities are no longer required to submit Notifications of Compliance Status.
e After full implementation, existing facilities are no longer required to keep records of the notifications.
f We estimate 21 glass manufacturing facilities with 27 affected furnaces. It is assumed that 13 of the 27 affected furnaces can meet the emission limit without installation of a control device. It is assumed that each of the remaining 14 affected furnaces have automatic monitoring and recording systems.
g Since Initial Notification and Notifications of Compliance Status are not expected for existing facilities after full implementation, transmittal of these items is not expected.
h After full implementation, training is not expected to occur at existing facilities.
i Because the data are already collected by respondents as required by the existing permit requirements, no costs or burden are associated with these information collection activities for clay ceramics manufacturing and secondary nonferrous metals processing.
j Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 2: Table 2

Table 2: Average Annual EPA Burden and Cost – NESHAP for Clay Ceramics Manufacturing, Glass Manufacturing, and Secondary Nonferrous Metals Processing (40 CFR Part 63, Subparts RRRRRR, SSSSSS, and TTTTTT) (Renewal)
					47.62	64.16	25.76
Burden Item	(A) EPA Hours per Occurrence	(B) Number of Occurrences per Plant per Year	(C) EPA Hours per Year (C=AxB)	(D) Plants per Year	(E) Technical Hours per Year (E=CxD)	(F) Management Hours per Year (F=Ex0.05)	(G) Clerical Hours per Year (G=Ex0.1)	(H) Costs per Year a
Attend performance test b	16	1	16	1	16	0.8	1.6	$854.46
Report review:
Initial notification of applicability c	2	1	2	0	0	0	0	$0.00
Notification of performance test d
Notification of compliance status e	4	1	4	0	0	0	0	$0.00
Travel expenses for tests attended f								$500
TOTAL ANNUAL BURDEN (rounded) g					18			$1,350
Assumptions:
a This ICR uses the following average hourly labor rates: $64.16 for managerial (GS-13, Step 5, $40.10×1.6), $47.62 (GS-12, Step 1, $29.76×1.6) for technical and $25.76 (GS-6, Step 3, $16.10×1.6) for clerical. These rates are from the Office of Personnel Management (OPM), 2016 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.
b Assumes Agency personnel will attend the performance test for one affected source per year. This only applies for glass manufacturing area sources.
c After full implementation, existing facilities are not required to submit Initial Notifications..
d Not required
e After full implementation, existing facilities are not required to submit Notifications of Compliance Status.
f Assumes Agency personnel (1 person) will spend 2 days per plant, at $50 per diem per day, and $400 transportation expense per round trip to attend performance tests.
g Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.