| Table 1: Annual Respondent Burden and Cost – NESHAP for Refractory Products Manufacturing (40 CFR Part 63, Subpart SSSSS) (Renewal) |
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117.92 |
147.4 |
57.02 |
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| Burden item |
(A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
(H) |
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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) |
Cost, $ b |
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| 1. Applications |
N/A |
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| 2. Survey and Studies |
N/A |
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| 3. Reporting Requirements |
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| A. Familiarization with rule requirements |
0.5 |
1 |
0.5 |
8 |
4 |
0.2 |
0.4 |
$523.97 |
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| B. Required activities |
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| Develop a startup, shutdown, malfunction plan |
32 |
1 |
32 |
0 |
0 |
0 |
0 |
$0 |
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| Develop an operation, maintenance, monitoring plan |
32 |
1 |
32 |
0 |
0 |
0 |
0 |
$0 |
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| Initial performance tests and reports |
24 |
1 |
24 |
0 |
0 |
0 |
0 |
$0 |
<-- Note to EPA: New line, hours are based on OSWI NSPS/EG values |
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| Initial CEMS demonstration c |
229 |
1 |
229 |
0 |
0 |
0 |
0 |
$0 |
<-- Note to EPA: Added costing for CEMS, but the assumption is that no one is using CEMS and no new sources at this time. |
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| Quarterly Appendix F audits of CEMS (THC) c |
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| a) RATA audit (one per year) |
4 |
1 |
4 |
0 |
0 |
0 |
0 |
$0 |
<-- Note to EPA: Added costing for CEMS, but the assumption is that no one is using CEMS, required for only a very narrow set of sources complying with a non-standard CD or invoking process changes. |
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| b) RAA audit (three per year) |
4 |
3 |
12 |
0 |
0 |
0 |
0 |
$0 |
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| c) Daily calibration and operation |
1 |
365 |
365 |
0 |
0 |
0 |
0 |
$0 |
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| C. Create information |
See 3B |
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| D. Gather existing information |
See 3B |
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| E. Write report |
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| Notification of applicability |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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| Notification of construction/reconstruction |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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| Notification of anticipated startup |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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| Notification of actual startup |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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| Notification of performance test |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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| Notification of compliance status |
16 |
1 |
16 |
0 |
0 |
0 |
0 |
$0 |
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| Notification of intent to use alternative fuel d |
2 |
1 |
2 |
3 |
6 |
0.3 |
0.6 |
$785.95 |
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| Report of deviations e |
16 |
1 |
16 |
1 |
16 |
0.8 |
1.6 |
$2,095.87 |
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| Report of no deviations f |
8 |
2 |
16 |
7 |
112 |
5.6 |
11.2 |
$14,671.10 |
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| Startup, shutdown, malfunction report g |
8 |
1 |
8 |
1 |
8 |
0.4 |
0.8 |
$1,047.94 |
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| Report of alternative fuel use h |
4 |
1 |
4 |
3 |
12 |
0.6 |
1.2 |
$1,571.90 |
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| Subtotal for Reporting Requirements |
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182 |
$20,697 |
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| 4. Recordkeeping Requirements |
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| A. Familiarization with rule requirements |
See 3A |
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<-- Note: The previous ICR included 4 hours of burden per occurance here, and doublecounted/overestimated the burden already included in 3A. |
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| B. Plan activities |
See 4E |
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| C. Implement activities |
See 4E |
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| D. Develop record system |
See 4E |
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| E. Time to enter information |
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| Records of all information required by standards i |
0.25 |
52 |
13 |
8 |
104 |
5.2 |
10.4 |
$13,623.17 |
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| F. Time to train personnel |
20 |
1 |
20 |
0 |
0 |
0 |
0 |
$0 |
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| G. Time to adjust existing ways to comply with previously applicable requirements |
N/A |
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| H. Time to transmit or disclose information j |
0.25 |
2 |
0.5 |
8 |
4 |
0.2 |
0.4 |
$523.97 |
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| I. Time for audits |
N/A |
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| Subtotal for Recordkeeping Requirements |
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124 |
$14,147 |
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| TOTAL ANNUAL BURDEN AND COSTS (rounded): k |
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306 |
$34,800 |
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| TOTAL CAPITAL/O&M COST (rounded): k |
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$3,040 |
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| GRAND TOTAL (rounded): k |
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$37,800 |
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14 |
hr/resp |
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| Assumptions: |
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| a We have assumed that the average number of respondents that will be subject to the rule will be eight. There will be no additional new source per year that will become subject to the rule over the three-year period of this ICR. |
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| 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. |
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| c We have assumed that there are no existing respondents required to comply using THC CEMS. |
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| d We have assumed that three respondents will use alternative fuel once per year and will have to submit notification of intent to use alternative fuel. |
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| e We have assumed that one respondent will report a deviation once a year. |
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| f We have assumed that seven respondents will report no deviations on a semiannual basis. |
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| g It is assumed that one respondent will have a startup, shutdown, malfunction (SSM) occur and be required to submit an immediate SSM report. |
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| h We have assumed that three respondents will report on alternative fuel usage once a year. |
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| i We have assumed that information will be recorded once per week for 52 weeks per year. |
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| j We have assumed that it will take 0.25 hours for information to be transmitted or disclosed. |
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| k Totals have been rounded to 3 significant values. Figures may not add exactly due to rounding. |
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| Table 2: Average Annual EPA Burden and Cost – NESHAP for Refractory Products Manufacturing (40 CFR Part 63, Subpart SSSSS) (Renewal) |
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48.75 |
65.71 |
26.38 |
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| Activity |
(A) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
(H) |
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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 |
| Attend initial performance test |
40 |
1 |
40 |
0 |
0 |
0 |
0 |
$0 |
| Attend repeat performance test |
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| Retesting preparation |
8 |
1 |
8 |
0 |
0 |
0 |
0 |
$0 |
| Retesting |
40 |
1 |
40 |
0 |
0 |
0 |
0 |
$0 |
| Report Review |
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| Notification of applicability |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
| Notification of construction/reconstruction |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
| Notification of anticipated startup |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
| Notification of actual startup |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
| Notification of initial performance test |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
| Notification of compliance status |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
| Notification of intent to use alternative fuel c |
2 |
1 |
2 |
3 |
6 |
0.3 |
0.6 |
$328.04 |
| Repeat performance test report |
40 |
1 |
40 |
0 |
0 |
0 |
0 |
$0 |
| Semiannual compliance reports |
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| Deviation d |
16 |
1 |
16 |
1 |
16 |
0.8 |
1.6 |
$874.78 |
| No Deviation e |
8 |
2 |
16 |
7 |
112 |
5.6 |
11.2 |
$6,123.43 |
| Startup, shutdown, malfunction report f |
16 |
1 |
16 |
1 |
16 |
0.8 |
1.6 |
$874.78 |
| Notification of alternative fuel use g |
2 |
1 |
2 |
3 |
6 |
0.3 |
0.6 |
$328.04 |
| TOTAL ANNUAL BURDEN AND COST (rounded) h |
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179 |
$8,530 |
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| Assumptions: |
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| a We have assumed that the average number of respondents that will be subject to the rule will be eight. There will be no additional new source per year that will become subject to the rule over the three-year period of this ICR. |
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| 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 x 1.6), Technical rate of $48.75 (GS-12, Step 1, $30.47 x 1.6), and Clerical rate of $26.38 (GS-6, Step 3, $16.49 x 1.6). These rates are from the Office of Personnel Management (OPM) “2018 General Schedule” which excludes locality rates of pay. |
| c We have assumed that three respondents will use alternative fuel once per year and will have to submit notification of intent to use alternative fuel. |
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| d We have assumed that one respondent will report deviations once a year. |
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| e We have assumed that seven respondents will report no deviation on a semiannual basis. |
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| f It is assumed that one respondents will have a startup, shutdown, malfunction occur. |
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| g We have assumed that three respondents will report on alternative fuel usage once a year. |
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| h Totals have been rounded to 3 significant values. Figures may not add exactly due to rounding. |
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