Burden Calculation Tables

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Overview

Table 1
Table 2
Capital-O&M

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Sheet 1: Table 1

Table 1: Annual Respondent Burden and Cost – NESHAP for Integrated Iron and Steel Manufacturing (40 CFR Part 63, Subpart FFFFF) (Renewal)
					$117.92	$147.40	$57.02	Labor Cost Per Hour		These rates were updated 11/15/18 to match the United States Department of Labor, Bureau of Labor Statistics, June 2018, “Table 2. Civilian Workers, by occupational and industry group
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
1. Applications	N/A
2. Survey and Studies	N/A
3. Reporting Requirements
A. Familiarization with rule requirements	2	1	2	12	24	1.2	2.4	$3,143.81
B. Required activities c
i. Method 5 performance test d	40	7.6	304	12	3,648	182.4	364.8	$477,858.82
ii. Method 9 performance test d	8	3.6	28.8	12	345.6	17.28	34.56	$45,270.84
iii. Method 9071B performance test	2	365	730	4	2,920	146.0	292	$382,496.64
iv. Startup, shutdown, malfunction plan e	40	1	40	0	0	0	0	$0
v. Inspection and maintenance of capture systems and control devices	2	12	24	12	288	14.4	28.8	$37,725.70
C. Gather existing information	See 4D, 4E
D. Write report c
i. Notification of applicability e	2	1	2	0	0	0	0	$0
ii. Notification of compliance status e	2	1	2	0	0	0	0	$0
iii. Notification of intent to construct a major source and review application e	4	1	4	0	0	0	0	$0
iv. Notification of initial construction/reconstruction e	4	1	4	0	0			$0
v. Notification of actual startup e	4	1	4	0	0	0	0	$0
vi. Notification of performance test e	4	1	4	0	0	0	0	$0
vii. Reports of performance test results	See 3B, 4E
viii. Semiannual compliance reports	40	2	80	12	960	48	96	$125,752.32
ix. Startup, shutdown, malfunction report f	4	1	4	1	4	0.2	0.4	$523.97
Subtotal for Reporting Requirements					9,418			$1,072,772
4. Recordkeeping Requirements
A. Familiarization with rule requirements	See 3A
B. Plan activities e	10	1	10	0	0	0	0	$0
C. Implement activities	See 3B
D. Develop record system	N/A
E. Time to enter and transmit information g	3.25	52	169	12	2,028	101.4	202.8	$265,651.78
F. Time to train personnel e	3	1	3	0	0	0	0	$0
G. Time for audits	N/A
Subtotal for Recordkeeping Requirements					2,332			$265,652
TOTAL LABOR BURDEN AND COST (rounded) h					11,800			$1,340,000
TOTAL CAPITAL AND O&M COST (rounded) h								$52,700
GRAND TOTAL (rounded) h								$1,390,000		393
										hr/resp
Assumptions:
a There are approximately 12 existing sources currently subject to this rule. There will be no additional new source that will become subject to the rule each year over the three-year period of this ICR.
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 Monitoring and recordkeeping of operations for respondents will include monthly inspection of capture and control systems; daily testing of oil content for the sinter plant feed (4 plants [from the composite of three samples taken at 8-hour intervals]) to compute the 30-day rolling average oil content for each operating day; and every 2.5 years, each emission point must be sampled by Method 5 for particulate matter and Method 9 for opacity observations to determine the opacity of fugitive emissions (12 plants).
d We have assumed that there is an average of 7.6 emission points per respondent that need to be sampled using Method 5 and 3.6 emission points per respondent to need to be sampled using Method 9.
e These requirements are one-time requirements that apply to new respondents. There are no new respondents estimated over the 3 year period of this ICR.
f We have assumed that one respondent per year will have at least one startup, shutdown, or malfunction (SSM) that is not managed according to the SSM plan.
g We have assumed that it takes each respondent approximately 3.25 hours per week to record and transmit information.
h Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 2: Table 2

Table 2: Average Annual EPA Burden and Cost – Average Annual EPA Burden and Cost − NESHAP for Integrated Iron and Steel Manufacturing (40 CFR Part 63, Subpart FFFFF) (Renewal)
					$48.75	$65.71	$26.38	Labor Cost per Hour		These rates were updated 11/15/18 to match the rates from the Office of Personnel Management (OPM), 2018 General Schedule.
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
New Respondents c
i. Notification of compliance status	4	1	4	0	0	0	0	$0
ii. Notification of intent to construct a major source and review application	4	1	4	0	0	0	0	$0
iii. Notification of start of construction	2	1	2	0	0	0	0	$0
iv. Notification of actual startup	2	1	2	0	0	0	0	$0
v. Notification of initial performance test and test plan	4	1	4	0	0	0	0	$0
Existing Respondents					0	0	0	$0
i. Performance test report for Method 5 and Method 9 d	20	0.4	8	12	96	4.8	9.6	$5,248.66
ii. Review semiannual compliance reports e	8	2	16	12	192	9.6	19.2	$10,497.31
iii. Review of startup, shutdown, and malfunction reports f	4	1	4	1	4	0.2	0.4	$218.69
TOTAL ANNUAL BURDEN AND COST (rounded) g					336			$16,000
Assumptions:
a There are approximately 12 existing sources currently subject to this rule. There will be no additional new source that will become subject to the rule each year over the three-year period of this ICR.
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 These requirements are one-time requirements that apply to new respondents. There are no new respondents estimated over the 3 year period of this ICR.
d Every 2.5 years (or about 0.4 times per year, if averaged over the three-year period of ICR), respondents must sample each emission point using Method 5 for particulate matter and Method 9 for opacity observations, and submit a report with results.
e Sources are required to submit semiannual compliance reports.
f We have assumed that one respondent per year will have at least one startup, shutdown, or malfunction (SSM) that is not managed according to the SSM plan.
g Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: Capital-O&M

(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,
Leak detectors	$9,000	0	0	$2,389	12	$28,668
Continuous opacity monitors	$37,000	0	0	$8,000	3	$24,000
TOTAL						$52,700