Burden Cost Tables

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Overview

1a
1b
1c
2
Responses
Working Respondent

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Sheet 1: 1a

Table 1a: Annual Respondent Burden and Cost for Small Foundries – NESHAP for Iron and Steel Foundry Area Sources (40 CFR Part 63, Subpart ZZZZZ) (Renewal)
					112.98	149.35	54.81
Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical person- hours per year (E=CxD)	(F) Management person hours per year (Ex0.05)	(G) Clerical person hours per year (Ex0.1)	(H) Total Cost per year b	ERG comment on changes
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 Requirementsa	1	1	1	316	316	15.8	31.6	$39,793.41	added respondent burden and referenced footnote a, but decreased this burden from 4 to 1 hr for ongoing burden
B. Required activities
Repeat performance tests for opacitye	0.1	2	0.2	316	63.2	3.16	6.32	$7,958.68
Scrap specificationsg	4	1	4	0	0	0	0	$0
Monthly emission averaging calculation	0.25	12	3	316	948	47.4	94.8	$119,380.22	do not see rolling average in rule, just emission averaging; monthly basis
No methanol binder formulation c	0	0	0	0	0	0	0	$0
C. Create information	See 4B
D. Gather existing information	See 4B
E. Write report	See 4B
Initial notification of applicabilityg	2	1	2	0	0	0	0	$0
Notification of compliance statusg	4	1	4	0	0	0	0	$0
Deviations reporta	1	1	1	158	158	7.9	15.8	$19,896.70	added footnote a which describes assumption of half the sources submitting a deviations report
Notification of construction/reconstructiong	N/A								added footnote g since this is one-time
Notification of anticipated startupg	N/A								This is no longer required in the General Provisions, it has been reserved and removed, so removed from this table.
Notification of actual startupg	N/A								added footnote g since this is one-time
Notification of foundry reclassificationf	1	0	0	0	0	0	0	$0
Request for compliance extensiong	N/A								added footnote g since this is one-time
Notification of repeat performance teste	N/A								this was the line item for footnote E which talks about opacity and lack of need for separate notification
Site specific test plang	N/A								added footnote g since this is one-time
Notification of performance evaluationg	N/A								added footnote g since this is one-time
Quality assurance plan for CEMS/COMSg	N/A								added footnote g since this is one-time
NESHAP waiver requestg	N/A								added footnote g since this is one-time
Startup, shutdown, and malfunction plan/reportsh	N/A								new footnote H since we did not assume any small sources would have to write this report
Semiannual excess emissions reportsh	N/A								new footnote H since we did not assume any small sources would have to write this report
Subtotal for Reporting Requirements					1,708			$187,029
5. Recordkeeping Requirements
A. Familiarization with Regulatory Requirements	See 4A
B. Plan activities	See 4A
C. Implement activities	See 4A
D Develop record system h	2	1	2	0	0	0	0	$0	added footnote g since this is one-time
E. Time to enter informationd	0.1	52	5.2	316	1,643.2	82.16	164.32	$206,925.71
F. Time to transmit or disclose information	0.25	2	0.5	316	158	7.90	15.80	$19,896.70
G. Time to adjust existing waysg	2	1	2	0	0	0	0	$0
F. Time to train personnel i	4	1	4	316	1,264	63.2	126.4	$159,174	added training time
G. Time for audits	N/A
Subtotal for Recordkeeping Requirements					3,525			$385,996
TOTAL LABOR BURDEN AND COST (rounded)j					5,230			$573,000
TOTAL CAPITAL AND O&M COST (rounded)j								$0
GRAND TOTAL (rounded)j					5,230			$573,000
Assumptions:
a Taking into account shutdown data for foundries, we have assumed that there are 392 existing iron and steel foundries that area sources. No new sources are projected during the 3-year term of this ICR. A total of 316 of the 392 facilities are small foundries and 76 are large foundries. For the purpose of deviation reports, 1 report per year is estimated for one-half of the small foundries. We assume all respondents will have to spend time familiarizing themselves with regulatory requirements each year.
b This ICR uses the following labor rates: The hourly wage rates used to represent respondent labor costs are: technical at $112.98, management at $149.35, and clerical at $54.81. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2017, “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.
c We have assumed that no burden would be incurred for this requirement because all small area source foundries are already meeting the no methanol requirement.
d We have assumed that small foundries must record information to demonstrate compliance with pollution prevention management practices for metallic scrap and binder formulations. In addition, they would need to record information to demonstrate compliance with the PM and opacity standards.										This footnote did not belong to any row. Looking at table 1b this was meant for the time to enter information' line item so I added a footnote D to that row above.
e We have assumed that all foundries would need to conduct performance tests to demonstrate compliance with the opacity limit in §63.10895(e) at least every 6 months and will not implement a process change likely to increase fugitive emissions over the 3 year period of this ICR. Opacity shall be determined as an average of 24 consecutive observations recorded at 15-second intervals, which average about 6 minutes (or 0.1 hrs). No separate notification required but the results of the opacity emissions will be reported.
f We have assumed that no foundries will be reclassified as large foundries.
g One-time only costs
h No excess emissions or startup shutdown reports were required from small foundries during this 3-year ICR renewal period.
i We have assumed that small foundries are expected to monitor visible emissions using a trained employee.
j Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. Small foundries are not assumed to incur any capital or O&M costs.

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Sheet 2: 1b

Table 1b: Annual Respondent Burden and Cost for Large Foundries – NESHAP for Iron and Steel Foundry Area Sources (40 CFR Part 63, Subpart ZZZZZ) (Renewal)
			June 2017:		112.98	149.35	54.81
Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical person- hours per year (E=CxD)	(F) Management person hours per year (Ex0.05)	(G) Clerical person hours per year (Ex0.1)	(H) Total Cost per year b	ERG comment on changes
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 Requirementsa	1	1	1	76	76	3.8	7.6	$9,570.57	Added this as an ongoing burden per OMB requirement, but decreased hours from 8 to 1 for re-familiarization of rule
B. Required activities
Repeat of Performance Test for PMd	24	0.2	4.8	76	364.8	18.24	36.48	$45,938.72
Repeat of Performance Test for Opacitye	0.1	2	0.2	76	15.2	0.76	1.52	$1,914.11
Scrap material specificationsg	4	1	4	0	0	0	0	$0
Prepare operation & maintenance plang	8	1	8	0	0	0	0	$0
No methanol binder formulation c	4	1	4	0.67	2.68	0.13	0.27	$337.49
Initial/subsequent performance tests d	0	0	0	0	0	0	0	$0
Initial and periodic inspections of PM control devices, monthly inspection of capture systems d	0	0	0	0	0	0	0	$0
Monthly emissions averaging calculations d	0	0	0	0	0	0	0	$0
C. Create information	See 4B
D. Gather existing information	See 4B
E. Write report	See 4B
Initial notification of applicabilityh	4	1	4	0	0	0	0	$0
Notification of compliance statush	8	1	8	0	0	0	0	$0
Notification of construction/reconstructionh	N/A
Notification of anticipated startuph	N/A								This is no longer required in the General Provisions, it has been reserved and removed, so removed from this table.
Notification of actual startuph	N/A
Notification of foundry reclassificationi	1	0	0	0	0	0	0	$0
Request for compliance extensionh	N/A								added footnote h, one-time
Notification of repeat PM performance test d	1	0.2	0.2	76	15.2	0.76	1.52	$1,914.11
Site specific test plan h	0	0	0	0	0	0	0	$0	added footnote h, one-time
Notification of performance evaluationh	N/A								added footnote h, one-time
Quality assurance plan for CEMS/COMSh	N/A								added footnote h, one-time
NESHAP waiver requesth	N/A								added footnote h, one-time
Startup, shutdown, and malfunction plan/reportsj	4	1	4	76	304	15.2	30.4	$38,282.26	added footnote j
Semiannual excess emissions reports j	2	2	4	76	304	15.2	30.4	$38,282.26	added footnote j
Subtotal for Reporting Requirements					1,244			$136,240
5. Recordkeeping Requirements
A. Familiarization with Regulatory Requirements	See 4A
B. Plan activities	See 4A
C. Implement activities	See 4A
D Develop record system h	4	1	4	0	0	0	0	0
E. Time to enter information f	0.5	52	26	76	1,976	98.8	197.6	$248,834.72
F. Time to transmit or disclose information	0.25	2	0.5	76	38	1.9	3.8	$4,785.28
G. Time to adjust existing waysh	2	1	2	0	0	0	0	$0
F. Time to train personnel g	4	1	4	76	304	15.2	30.4	$38,282.26
G. Time for audits	N/A
Subtotal for Recordkeeping Requirements					2,666			291,902
TOTAL LABOR BURDEN AND COST (rounded)k					3,910			428,000
TOTAL CAPITAL AND O&M COST (rounded)k								$0
GRAND TOTAL (rounded)k					3,910			$428,000
Assumptions:
a Taking into account shutdown data for foundries, we have assumed that there are 392 existing iron and steel foundries that area sources. No new sources are projected during the 3-year term of this ICR. A total of 316 of the 392 facilities are small foundries and 76 are large foundries. We assume all respondents will have to spend time familiarizing themselves with regulatory requirements each year.
b This ICR uses the following labor rates: The hourly wage rates used to represent respondent labor costs are: technical at $112.98, management at $149.35, and clerical at $54.81. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2017, “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.
c We assumed that two large area source foundries (2 foundries over 3 years = 0.67 foundries per year) are expected to have to change formulations to meet the no methanol requirement.
d We have assumed that large area source foundries will implement subsequent performance tests required by the rule for each metal melting furnace subject to a PM or total metal HAP limit in §63.10895(c) at least every 5 years (or 0.2 averaged on a yearly basis) and will not implement a performance test due to a change to an operating limit or a process change likely to increase HAP emissions over the period of this ICR. A notification is required.
e We have assumed that all foundries would need to conduct performance tests to demonstrate compliance with the opacity limit in §63.10895(e) at least every 6 months and will not implement a process change likely to increase fugitive emissions over the 3 year period of this ICR. Opacity shall be determined as an average of 24 consecutive observations recorded at 15-second intervals, which average about 6 minutes (or 0.1 hrs). No separate notification required.
f We have assumed that large foundries must record information to demonstrate compliance with pollution prevention management practices for metallic scrap and binder formulations and information to demonstrate compliance with monitoring; inspection; operation and maintenance; startups, shutdowns, and malfunctions; and other requirements of the General Provisions (40 CFR part 63, subpart A). In addition, record to record information to demonstrate compliance with the PM and opacity standards.
g We have assumed that large foundries are expected to monitor visible emissions using a trained employee.
h One-time only costs
i We have assumed that no foundries will be reclassified as small foundries.										new footnote i
j We have assumed that all large foundries will submit one startup shutdown malfunction report per year and all will submit semi-annual excess emission reports.										added footnote j
k Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. Large foundries are not assumed to incur any capital or O&M costs.										relabeled to k

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Sheet 3: 1c

Table 1c: Annual Respondent Burden and Cost for All Foundries – NESHAP for Iron and Steel Foundry Area Sources (40 CFR Part 63, Subpart ZZZZZ) (Renewal)
	Category	Reporting Hours	Recordkeeping Hours	Total Labor Hours	Labor Cost	Number of Response
	Small Foundry	1,708	3,525	5,230	$573,000	158
	Large Foundry	1,244	2,666	3,910	$428,000	243
	Total	2,952	6,191	9,140	$1,000,000	401
				23	hr per resp

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Sheet 4: 2

Table 2: Average Annual EPA Burden and Cost – NESHAP for Iron and Steel Foundry Area Sources (40 CFR Part 63, Subpart ZZZZZ) (Renewal)
				2017:	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 (AxB)	(D) Plants per year a	(E) Technical person-hours per year (CxD)	(F) Management person-hours per year (Ex0.05)	(G) Clerical person-hours per year (Ex0.1)	(H) Cost, $ b
Report Review:
Initial notification of applicability c	1	1	1	0	0	0	0	0
Deviation reportsa	1	1	1	158	158	7.9	15.8	$8,519.68
Startup, shutdown, malfunction plan/reporta	2	1	2	76	152	7.6	15.2	$8,196.14
Notification of compliance statusc	2	1	2	0	0	0	0	$0
Notification of performance testd	1	0.2	0.2	76	15.2	0.76	1.52	$819.61
Semiannual excess emissions reporta	2	2	4	76	304	15.2	30.4	$16,392.29
TOTAL BURDEN AND COST (rounded)e					724			$33,900
Assumptions:
a Taking into account shutdown data for foundries, we have assumed that there are 392 existing iron and steel foundries that are area sources. No new sources are projected during the 3-year term of this ICR. A total of 316 of the 392 facilities are small foundries and 76 are large foundries. For the purpose of deviation reports, 1 report per year is estimated for one-half of the small foundries. For SSM plan/reports and semiannual reports all large foundries (76 respondents) will submit reports.
b This ICR uses the following average hourly labor rates (GS-13, Step 5, $ x 1.6): 64.80 for managerial, $48.08 for technical and $26.02 for clerical. These rates are from the Office of Personnel Management (OPM) "2017 General Schedule" which excludes locality rates of pay.
c One-time only costs
d We have assumed that large area source foundries will implement subsequent performance tests required by the rule for each metal melting furnace subject to a PM or total metal HAP limit in §63.10895(c) at least every 5 years (or 0.2 averaged on a yearly basis) and will not implement a performance test due to change to an operating limit or a process change likely to increase HAP emissions.
e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 5: Responses

(A)	(B)	(C)	(D)	(E)
Information Collection Activity	Number of Respondents	Number of Responses	Number of Existing Respondents That Keep Records But Do Not Submit Reports	Total Annual Responses
				E=(BxC)+D
Initial Notification	0	0	0	0
Notification of Compliance Status	0	0	0	0
Notification of Foundry Reclassification	0	0	0	0
Deviations Report (small foundries)	158	1	0	158
Repeat of Performance Test for PM (large foundries)a	76	0.2	0	15.2
SSM plan (large foundries)	76	1	0	76
Semiannual compliance reports (large foundries)	76	2	0	152
			Total	401

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Sheet 6: Working Respondent

	Old ICR (2267.04)				New ICR (2267.05)
	Number of Sources	Distribution	Number of Small Entity	Basis	Number of Sources	Basis	Number of Small Entity	Basis
Total	427	1.00	330		392	total foundries taking into account 35 shutdowns since 2008 per Steel Founders' Society of America consultation response
small	344	0.81	292	85% of small foundries are small entities	316	revised small count	269	85% of small foundries are small entities
large	83	0.19	37	45% of large foundries are small entities	76	revised large count	34	45% of large foundries are small entities