Burden Calculation Table

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Overview

Respondents - Table 1
Agency - Table 2
Respondents - O&M

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Sheet 1: Respondents - Table 1

Table 1: Annual Respondent Burden and Cost – NESHAP for Steel Pickling, HCl Process Facilities and Hydrochloric Acid Regeneration Plants (40 CFR Part 63, Subpart CCC) (Renewal)
					$112.98	$149.35	$54.81
Burden item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Person hours per occurrence	No. of occurrences per respondent per year	Person hours per respondent per year (C=AxB)	Respondents per year a	Technical person- hours per year (E=CxD)	Management person hours per year (Ex0.05)	Clerical person hours per year (Ex0.1)	Total Cost per year b		Total Number of Respondents			Respondant Rates (Source: United States Department of Labor, Bureau of Labor Statistics, June 2017, “Table 2. Civilian Workers, by occupational and industry group.”)
1. Applications	N/A									Number of sources established in 2012 final rule amendments	100		Labor Type	Total Compensation ($/hr)	Loaded Rate (Rate + 110%rate)
2. Survey and Studies	N/A												Mgmt.	$71.12	$149.35
3. Reporting requirements													Tech.	$53.80	$112.98
A. Familiarization with regulatory requirements	1	1	1	100	100	5	10	$12,593					Cler.	$26.10	$54.81
B. Required activities
Initial performance test c	125	1	125	0	0	0	0	$0
Repeat initial performance test c	125	0.2	25	0	0	0	0	$0
Periodic performance tests d, e	125	1	125	100	12500	625	1250	$1,574,107.50
Operation and maintenance plan	40	1	40	0	0	0	0	$0
Operation and maintenance plan revision f	Note to OC: The table from 1821.08 includes burden for revising the O&M plan. However, the rule includes no requirement to get approval for, or to revise, the operation and maintenance plan. The current ICR approval also specifies 40 hours to revise the plan. We have reduced the estimate to 20 hours because the burden to revise the plan should be signifiantly less than the burden to draft the original plan, which is 40 hours, however, EPA may wish to revisit including any burden for this line item 20	1	20	10	200	10	20	$25,185.72
C. Create information	See 3B
D. Gather existing information	See 3B
E. Write Report
Notification of applicability g	2	1	2	0	0	0	0	$0
Notification of construction/reconstruction g	2	1	2	0	0	0	0	$0
Notification of anticipated startup g	2	1	2	0	0	0	0	$0
Notification of actual startup g	2	1	2	0	0	0	0	$0
Notification of special compliance requirements	N/A
Notification of initial performance test g	2	1	2	0	0	0	0	$0
Notification of compliance status g	4	1	4	0	0	0	0	$0
NESHAP waiver application h	N/A
Report of initial and periodic performance tests	See 3B
Report of monitoring exceedances, including malfunctions i	16	2	32	20	640	32	64	$80,594.30
Report of no excess emissions j	8	2	16	80	1280	64	128	$161,188.61
Reporting Subtotal					16,928			$1,853,669
4. Recordkeeping requirements
A. Familiarization with regulatory requirements	See 3A
B. Plan activities	See 3B
C. Implement Activities	See 3B
D. Develop record system	N/A
E. Time to enter information
Records of all information required by standards k	3	52	156	100	15600	780	1560	$1,964,486.16
F. Time to train personnel	4	1	4	0	0	0	0	$0
G. Time to transmit or disclose information l	0.25	3	0.75	100	75	3.75	7.5	$9,444.65
H. Time for audits	N/A
Recordkeeping Subtotal					18,026			$1,973,931
TOTAL LABOR BURDEN AND COST (rounded) m					35,000			$3,830,000
TOTAL CAPITAL and O&M COSTS (rounded) m								$10,600
GRAND TOTAL (rounded) m						35,000		$3,840,000
							total # Responses	200
Assumptions:							hr/response	175		Prev ICR:	35,069 hrs	$3,540,000
a We have assumed that there are approximately 100 respondents subject to the standard (95 steel pickling and 5 acid regeneration facilities). We have further assumed that no additional respondent per year will become subject to the regulation in the next three years. Since there are no new respondents estimated, initial performance tests, initial operation and maintenance plans, and initial notifications do not apply.
b This ICR uses the following labor rates: $149.35 per hour for Executive, Administrative, and Managerial labor; $112.98 per hour for Technical labor, and $54.81 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2017 “Table 12: 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 each new respondent will be required to conduct an initial performance test and 20 percent will have to repeat this test. Since there are no new respondents estimated, these requirements do not apply.
d Each respondent is required to conduct a periodic performance test to measure either: (1) the HCl mass flows at the control device inlet and outlet or (2) the concentration of HCl exiting the control device. The test results must be reported within 2 months of the test date. Periodic performance tests must be conducted either annually or according to an alternative schedule that is approved by the applicable permitting authority, but no less frequently than every 2.5 years or twice per title V permit term. We are assuming that all periodic performance tests are conducted annually.
e We have assumed that it will take 125 hours for each respondent to complete the periodic performance test and report.
f We have assumed that 10 percent of respondents must write a revised operation and maintenance plan for each emission control device.
g We have assumed that all new sources will be required to meet initial notification requirements. Since there are no new respondents estimated, these requirements do not apply.
h We have assumed that no respondent will request a NESHAP waiver application.
i We have assumed that 20 percent of respondents will report excess emissions on a semiannual basis.
j We have assumed that 80 percent of respondents will report no excess emissions on a semiannual basis.
k We have assumed that each respondent will take three hours each week to record all information required by the standard.
l We have assumed that each respondent will take 15 minutes three times per year to transmit or disclose information.
m Totals have been rounded to 3 significant values. Figures may not add exactly due to rounding.

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Sheet 2: Agency - Table 2

Table 2: Average Annual EPA Burden and Cost − NESHAP for Steel Pickling, HCl Process Facilities and Hydrochloric Acid Regeneration Plants (40 CFR Part 63, Subpart CCC) (Renewal)
					$48.08	$64.80	$26.02
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			Hourly Mean Wage	With Fringe & Overhead	Agency Rates Source: Office of Personnel Management (OPM), 2017 General Schedule
Report Review										(GS- 12, step 1) - Tech.	30.05	$48.08
New Sources										(GS- 13, step 5) - Mgmt.	40.5	$64.80
Notification of applicability c	2	1	2	0	0	0	0	$0		(GS-6, step 3) - Cler.	16.26	$26.02
Notification of construction/ reconstruction c	2	1	2	0	0	0	0	$0
Notification of actual startup c	2	1	2	0	0	0	0	$0
Notification of special compliance requirements	N/A
Notification of initial performance test c	2	1	2	0	0	0	0	$0
Notification of compliance status c	2	1	2	0	0	0	0	$0
Review of initial performance test report d	4	1	4	0	0	0	0	$0
Review of repeat initial performance test report d, e	4	0.2	0.8	0	0	0	0	$0
Existing Sources
Review of excess emissions report f	4	2	8	20	160	8	16	$8,211.20
Review of no excess emissions report g	2	2	4	80	320	16	32	$17,254.91
Note to OC: Error in previous ICR renewal: Significant increase in agency burden because this report was missing from this table. Without this added row, the burden increase (due to labor rates increasing) would have been $25,900. Review of periodic performance test report h	4	1	4	100	400	20	40	$21,568.64
Review of waiver application i	2	1	2	0	0	0	0	$0
TOTAL (rounded) j					1,010			$47,000
											Prev ICR:	552	$25,100
Assumptions:
a We have assumed that there are approximately 100 respondents subject to the standard. We have further assumed that no additional respondent per year will become subject to the regulation in the next three years. Since there are no new respondents estimated, initial performance tests and initial notifications do not apply.
b This cost is based on the following hourly labor rates times a 1.6 benefits multiplication factor to account for government overhead expenses: $64.80 for Managerial (GS-13, Step 5), $48.08 for Technical (GS-12, Step 1) and $26.02 Clerical (GS-6, Step 3). These rates are from the Office of Personnel Management (OPM) “2017 General Schedule”, which excludes locality rates of pay.
c We have assumed that all new sources will be required to meet initial notification requirements. Since there are no new respondents estimated, these requirements do not apply.
d We have assumed that each respondent will take 4 hours to participate in the performance tests. Since there are no new respondents estimated, these requirements do not apply.
e We have assumed that 20 percent of new respondents will have to repeat the performance tests due to failure. Since there are no new respondents estimated, these requirements do not apply.
f We have assumed that 20 percent of respondents will report excess emissions on a semiannual basis.
g We have assumed that 80 percent of respondents will report no excess emissions on a semiannual basis.
h Periodic performance tests are submitted at least twice every 5 years (title V permit term), but may be required by the permitting authority to be submitted as frequently as annually. We assume that all periodic performance tests are conducted annually.
i We have assumed that no waiver application is expected.
j Totals have been rounded to 3 significant values. Figures may not add exactly due to rounding.

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Sheet 3: Respondents - O&M

Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A)	(B)	(C)	(D)	(E)	(F)	(G)
Continuous Monitoring Device	Capital/Startup Cost for One Respondent	Number of New Respondents	Total Capital/Startup Cost (B X C)	Annual O&M Costs for One Respondent	Number of Respondents with O&M	Total O&M Costs (E X F)
Flow-meters with high/low alarms	$830	0	$0	$106	100	$10,600