Burden Calculation Tables

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Overview

# Respondents
# Responses
Respondent Burden
Agency Burden

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Sheet 1: # Respondents

Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
	(A)	(B)	(C)	(D)	(E)
Year	Number of New Respondents	Number of Existing Respondents	Number of Existing Respondents that keep records but do not submit reports	Number of Existing Respondents That Are Also New Respondents	Number of Respondents
					(E=A+B+C-D)
1	0	2	0	0	2
2	0	2	0	0	2
3	0	2	0	0	2
Average	0	2	0	0	2

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Sheet 2: # Responses

Total Annual Responses
(A) Information Collection Activity	(B) Number of Respondents	(C) Number of Responses	(D) Number of Existing Respondents That Keep Records But Do Not Submit Reports	(E) Total Annual Responses E=(BxC)+D
Initial notifications	0	5	0	0
Notification of annual performance test	2	1	0	2
Notification of opacity and visible emissions observations	2	1	0	2
Report of annual performance test results/opacity observations	2	1	0	2
Semiannual reports	2	2	0	4
Quarterly reports	2	4	0	8
Annual compliance status certification	2	1	0	2
			Total	20

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Sheet 3: Respondent Burden

Table 1: Annual Respondent Burden and Cost – NESHAP for Ferroalloys Production: Ferromanganese and Silicomanganese (40 CFR Part 63, Subpart XXX) (Renewal)
Burden item	A	B	C	D	E	F	G	H
	Person-hours per occurrence	Annual occurrences per respondent	Person-hours per respondent per year (AxB)	Respondents per year a	Technical hours per year (CxD)	Management hours per year (Ex0.05)	Clerical hours per year (Ex0.10)	Annual cost ($) b
1. Applications	N/A
2. Surveys and studies	N/A
3. Acquisition, installation, and utilization of technology and systems	N/A									Labor Rates		Notes:
4. Reporting requirements c										Technical	117.92	updated 9/20/18 to match the United States Department of Labor, Bureau of Labor Statistics, June 2018, “Table 2. Civilian Workers, by occupational and industry group
A. Familiarize with Regulatory Requirements	1	1	1	2	2	0.1	0.2	$261.98		Management	147.40	updated 9/20/18 to match the United States Department of Labor, Bureau of Labor Statistics, June 2018, “Table 2. Civilian Workers, by occupational and industry group
B. Required activities	See 5C									Clerical	57.02	updated 9/20/18 to match the United States Department of Labor, Bureau of Labor Statistics, June 2018, “Table 2. Civilian Workers, by occupational and industry group
C. Create information	See 5C
D. Gather information	See 5C
E. Report preparation
i. Initial notifications	N/A									Source Type	No.
ii. Notification of reconstruction/modification	N/A									Existing	2
iii. Notification of annual performance test	2	1	2	2	4	0.2	0.4	$523.97		New	0
iv. Notification of opacity and visible observations	2	1	2	2	4	0.2	0.4	$523.97
v. Report of performance test results/opacity observations	5	1	5	2	10	0.50	1.0	$1,309.92
vi. Periodic startup, shutdown and malfunction reports	10	2	20	2	40	2	4	$5,239.68
vii. Capture hood inspection report	4	2	8	2	16	0.8	1.6	$2,095.87		59	hrs/response
viii. Summary report of maintenance records	4	2	8	2	16	0.8	1.6	$2,095.87
ix. Fugitive dust operations report	4	2	8	2	16	0.8	1.6	$2,095.87
x. Quarterly excess emissions report	4	4	16	2	32	1.6	3.2	$4,191.74
xi. Annual compliance status certification	2	1	2	2	4	0.2	0.4	$523.97
Subtotal for Reporting Requirements					166			$18,862.85
5. Recordkeeping requirements
A. Familiarize with Regulatory Requirements	See 4A
B. Plan activities	10	1	10	2	20	1.0	2	$2,619.84
C. Implement activities
i. Control devices
Annual Performance tests for submerged arc furnace control devices	50	1	50	2	100	5.0	10	$13,099.20
Baghouse monitoring
Daily	0.5	350	175	2	350	17.50	35.0	$45,847.20
Weekly	0.1	50	5	2	10	0.50	1.0	$1,309.92
Monthly	0.1	12	1.2	2	2.4	0.12	0.24	$314.38
Quarterly	0.1	4	0.4	2	0.8	0.04	0.08	$104.79
Semiannually	0.1	2	0.2	2	0.4	0.02	0.04	$52.40
Parameter monitoring	0.1	1,050	105	2	210	10.50	21.0	$27,508.32
ii. Monthly capture system inspection	2	12	24	2	48	2.4	4.8	$6,287.62
iii. Opacity violation - scrubber	2	1	2	2	4	0.2	0.4	$523.97
iv. Opacity violation - baghouse	2	20	40	2	80	4	8	$10,479.36
v. Monitoring violation - capture system	2	12	24	2	48	2.4	4.8	$6,287.62
D. Develop record system c	N/A
E. Enter and transmit information	See 5C
F. Personnel training	N/A
G. Adjust existing ways to comply with previously applicable requirements	N/A
H. Disclose information	N/A
I. Audits	N/A
Subtotal for Recordkeeping Requirements					1,005			$114,434.61
TOTAL LABOR BURDEN AND COST (rounded) d					1,170			$133,000
Capital and O&M Cost (rounded) d								$0
GRAND TOTAL (rounded) d								$133,000
Assumptions:
a There are two ferroalloy production facilities currently subject to the standard. No additional respondents will become subject to this regulation since industry growth is not expected in the next three years.
b This ICR uses the following labor rates: $147.40 per hour for Executive, Administrative, and Managerial labor; $117.92 per hour for Technical labor, and $57.02 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2018, “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 Initial notification and compliance demonstration requirements and activities including the development its of record systems, including the startup, shutdown and malfunction plan; the fugitive dust plan; and the control equipment/maintenance plan, are only required for new respondents. Since there are no new respondents anticipated over the next three years of this ICR, there is no burden estimated for these activities.
d Totals have been rounded to 3 significant values. Figures may not add exactly due to rounding.

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Sheet 4: Agency Burden

Table 2: Average Annual EPA Burden and Cost – NESHAP for Ferroalloys Production: Ferromanganese and Silicomanganese (40 CFR Part 63, Subpart XXX) (Renewal)
Burden item	A	B	C	D	E	F	G	H
	EPA person-hours per occurrence	Annual occurrences per respondent	EPA person-hours per respondent per year (AxB)	Respondents per year a	Technical hours per year (CxD)	Management hours per year (Ex0.05)	Clerical hours per year (Ex0.10)	Annual cost ($) b
1. Report reviews c										Labor Rates		Notes:
A. Initial notifications	N/A									Technical	48.75	Updated 9/20/18 to match the rates from the Office of Personnel Management (OPM), 2018 General Schedule.
B. Notification of reconstruction/modification	N/A									Management	65.71	Updated 9/20/18 to match the rates from the Office of Personnel Management (OPM), 2018 General Schedule.
C. Notification of annual performance test/opacity and visible emissions observations d	1	1	1	2	2	0.10	0.2	$109.35		Clerical	26.38	Updated 9/20/18 to match the rates from the Office of Personnel Management (OPM), 2018 General Schedule.
D. Report of performance test results/opacity observations	5	1	5	2	10	0.50	1.0	$546.74
E. Semiannual summary reports	10	2	20	2	40	2	4	$2,186.94
F. Quarterly excess emissions report	2	4	8	2	16	0.8	1.6	$874.78
G. Annual compliance status certification	2	1	2	2	4	0.2	0.4	$218.69
TOTAL ANNUAL COST (ROUNDED)e					83			$3,940
Assumptions:
a There are two ferroalloy production facilities currently subject to the standard. No additional respondents will become subject to this regulation since industry growth is not expected in the next three years.
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 $65.71 (GS-13, Step 5, $41.07 + 60%), Technical rate of $48.75 (GS-12, Step 1, $30.47 + 60%), and Clerical rate of $26.38 (GS-6, Step 3, $16.49 + 60%). These rates are from the Office of Personnel Management (OPM) “2018 General Schedule” which excludes locality rates of pay.
c Initial notification and compliance demonstration requirements and activities including the development its of record systems, including the startup, shutdown and malfunction plan; the fugitive dust plan; and the control equipment/maintenance plan, are only required for new respondents. Since there are no new respondents anticipated over the next three years of this ICR, there is no burden estimated for these activities.
d Notifications for performance testing and opacity and visible emissions observations are submitted concurrently for EPA review.
e Totals have been rounded to 3 significant values. Figures may not add exactly due to rounding.