Burden Calculations Tables

---

Overview

Industry
Agency

---

Sheet 1: Industry

					Sep 2016 Labor Rates
					108.28	144.33	53.34
Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (A x B)	(D) Respondents per yeara	(E) Technical person- hours per year (C x D)	(F) Management person hours per year (E x 0.05)	(G) Clerical person hours per year (E x 0.1)	(H) Total Cost per yearb
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. Familiarization with Regulatory Requirements	8	1	8	91	728	36.4	72.8	$87,964.60
B. Required activities
Initial performance tests c
Prepare scrap plan and scrap specificationsd	4	1	4	0	0	0	0	$0
C. Create information	See 4B
D. Gather existing information	See 4B
E. Write report	See 4B
Initial notification of applicabilityd	2	0	0	0	0	0	0	$0
Notification of compliance statusd	2	0	0	0	0	0	0	$0
Request for compliance extension	N/A
Notification of performance test c
Startup, shutdown, and malfunction plan/reportse	4	1	4	91	364	18.2	36.4	$43,982.30			SSM report	91
Semiannual excess emissions reportse	2	2	4	91	364	18.2	36.4	$43,982.30			Semiannual report	182
Subtotal for Reporting Requirements					1,674			$175,929			Total Responses	273
5. Recordkeeping Requirements											Hours per response	16.3
A. Familiarization with Regulatory Requirements	See 4A
B. Plan activities	See 4B
C. Implement activities	See 4B
D. Develop record system d	4	1	4	0	0	0	0	$0
E. Time to enter information f	0.5	52	26	91	2,366	118.3	236.6	$285,884.96
F. Time to transmit or disclose informationf	0.25	2	0.5	91	45.5	2.28	4.55	$5,497.79
G. Time to adjust existing waysd	2	1	2	0	0	0	0	$0
F. Time to train personneld	4	1	4	0	0	0	0	$0
G. Time for audits	N/A
Subtotal for Recordkeeping Requirements					2,773			$291,400
TOTAL LABOR BURDEN AND COST (rounded)g					4,450			$467,000
TOTAL CAPITAL AND O&M COST (rounded)g								$0
GRAND TOTAL (rounded)g								$467,000
Assumptions:
a There are 91 existing EAF steelmaking facilities and no new sources are estimated. We assume that each respondent will have to familiarize with the regulatory requirements each year.
b This ICR uses the following labor rates: $144.33 for managerial labor, $108.28 for technical labor, and $53.34 for clerical labor. These rates are from the U.S. Department of Labor, Bureau of Labor Statistics, September 2016. The rates have been increased by 60 percent to account for overhead.
c All plants have conducted performance tests during the implementation period of the rule.
d After full implementation, existing facilities are not expected to experience any burden from these activities and no new facilities are expected to become subject to the rule over the 3-year period.
e Sources are required include in their semiannual reports the number of mercury switches removed or the weight of mercury recovered from the switches and properly managed, the estimated number of vehicles processed, an estimate of the percent of mercury switches recovered, and a certification that the recovered mercury switches were recycled at RCRA-permitted facilities, if they are subject to a site-specific plan for mercury. In addition all sources must submit semiannual reports for the control of contaminants from scrap according to the requirements in §63.10(e). For start-up, shutdown, and malfunction, these semi-annual reports are only required if a startup or shutdown caused the source to exceed any applicable emission limitation in the relevant emission standards, or if a malfunction occurred during the reporting period. This ICR assumes each source had one six-month period during each year that required a report.
f Assumed that each facility will update records weekly. The only transmission is the semi-annual report and the annual SSM report.
g Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

---

Sheet 2: Agency

					2017 Schedule
					48.08	64.8	26.02
Activity	(A) EPA person- hours per occurrence	(B) No. of occurrences per plant per year	(C) EPA person- hours per plant per year (A x B)	(D) Plants per yeara	(E) Technical person- hours per year (C x D)	(F) Management person-hours per year (E x 0.05)	(G) Clerical person-hours per year (E x 0.1)	(H) Cost, $b
Report Review
Initial notification of applicability c	1	1	1	0	0	0	0	$0
Startup, shutdown, malfunction plan/reportd	2	1	2	91	182	9.1	18.2	$9,813.80
Notification of compliance statusc	1	1	1	0	0	0	0	$0
Semiannual excess emissions report	0.5	2	1	91	91	4.55	9.1	$4,906.90
TOTAL ANNUAL BURDEN AND COST (rounded)e					314			$14,700
a There are 91 existing EAF steelmaking facilities and no new sources are estimated.
b This ICR uses the following average hourly labor rates: $64.80 for managerial (GS-13, Step 5, $40.50 × 1.6), $48.08 (GS-12, Step 1, $30.05 × 1.6) for technical and $26.02 (GS-6, Step 3, $16.26 × 1.6) for clerical. These rates are from the Office of Personnel Management (OPM) “2017 General Schedule” which excludes locality rates of pay.
c After full implementation, the agency is not expected to experience any burden from these activities because existing facilities are not longer expected to submit Initial notifications of applicability or Notifications of compliance status. No new facilities are expected to become subject to the rule over the 3-year period.
d This ICR assumes each source had one six-month period during each year that required a report.
e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.