Burden Calculation Tables

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Overview

Table 1
Table 2
Additional

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Sheet 1: Table 1

Table 1: Annual Respondent Burden and Cost – NESHAP for Taconite Iron Ore Processing (40 CFR Part 63, Subpart RRRRR) (Renewal)
Burden Item	(A) Respondent Hours per Occurrence	(B) Number of Occurrences per Respondent per Year	(C) Hours per Respondent per Year (C=AxB)	(D) Number of Respondents per Year a	(E) Technical Hours per Year (E=CxD)	(F) Management Hours per Year (F=Ex0.05)	(G) Clerical Hours per Year (G=Ex0.1)	(H) Total Labor Costs per Year b
1. Applications	N/A									Labor Rates:
2. Survey and Studies	N/A									Management	$147.40
3. Reporting Requirements										Technical	$117.92
A. Familiarize with regulatory requirements c	2	1	2	7	14	0.7	1.4	$1,833.89		Clerical	$57.02
B. Required activities
Performance test – facility labor e	40	1	40	2.8	112	5.6	11.2	$14,671.10
Startup, shutdown, and malfunction plan	40	1	40	2.8	112	5.6	11.2	$14,671.10
C. Create information	See 4B
D. Gather existing information	See 4B
E. Write reports
Initial notification d	2	1	2	0	0	0	0	$0
Compliance extension request d	2	1	2	0	0	0	0	$0
Site-specific test plan f	40	1	40	0.56	22.4	1.12	2.24	$2,934.22
Operation and maintenance plan d, g	40	1	40	0	0	0	0	$0
Fugitive dust emission control plan d, h	20	1	20	0	0	0	0	$0
Site-specific monitoring plan d, i	80	1	80	0	0	0	0	$0
Semiannual compliance reports	8	2	16	7	112	5.6	11.2	$14,671.10
Petition for alternative monitoring requirements	40	1	40	0	0	0	0	$0
Notification of performance test j	4	3	12	2.8	33.6	1.68	3.36	$4,401.33
Subtotal for Reporting Requirements					467			$53,183
4. Recordkeeping requirements
A. Familiarize with regulatory requirements c	See 3A
B. Plan activities	3	1	3	0	0	0	0	$0
C. Develop record system	16	1	16	0	0	0	0	$0
D. Time to train personnel	3	1	3	0	0	0	0	$0
E. Time to transmit or disclose information	1	2	2	7	14	0.7	1.4	$1,833.89
F. Time for audits	N/A
Subtotal for Recordkeeping Requirements					16			$1,834
Total Labor Burden and Cost (rounded) k					483			$55,000
Total Capital and O&M Cost (rounded) k								$521,000		21
Grand Total (rounded) k								$576,000		hr/response
Assumptions:
a We have assumed that the average number of respondents that will be subject to the rule will be seven (the eight existing respondents, less the one facility that is idle). There will be no additional new sources per year that will become subject to the rule 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 This ICR assumes all respondents will have to familiarize with the regulatory requirements each year.
d This is a one-time activity.
e We have assumed that it will take 40 hours for each facility to complete performance test, and that performance tests are repeated every two of five years. Therefore, an average of 2.8 facilities per year will complete performance tests (2 performance test/5 years*7 facilities).
f We have assumed that 20 percent of all sources conducting performance tests will send in a site-specific test plan.
g We have assumed that each respondent will take 40 hours to write the operation and maintenance plan.
h We have assumed that each respondent will take 20 hours to write the fugitive dust emission control plan.
i We have assumed that each respondent will take 80 hours to complete the site-specific monitoring plan report.
j We have assumed that each respondent will take 4 hours to complete the notification of performance test report.
k 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 – NESHAP for Taconite Iron Ore Processing (40 CFR Part 63, Subpart RRRRR) (Renewal)
Burden Item	(A) EPA Hours per Occurrence	(B) Number of Occurrences per Plant per Year	(C) EPA Hours per Plant per Year (C=AxB)	(D) Plants per Year a	(E) Technical Hoursper Year (E=CxD)	(F) Management Hours per Year (F=Ex0.05)	(G) Clerical Hoursper Year (G=Ex0.1)	(H) Costs per Year ($) b
										Labor Rates:
Initial performance tests c, d	8	7	56	0	0	0	0	$0		Management	$65.71
Report Review										Technical	$48.75
Initial notification c	2	1	2	0	0	0	0	$0		Clerical	$26.38
Notification of initial performance test c	2	3	6	0	0	0	0	$0
Fugitive dust emissions control plan e	10	1	10	0	0	0	0	$0
Compliance extension request	2	1	2	0	0	0	0	$0
Site-specific test plan f	10	1	10	0.56	5.6	0.28	0.56	$306.17
Operation and maintenance plan c, f	10	1	10	0	0	0	0	$0
Site-specific monitoring plan c, f	10	1	10	0	0	0	0	$0
Petition for alternative monitoring requirements	5	1	5	0	0	0	0	$0
Review of semiannual compliance report	4	2	8	7	56	2.8	5.6	$3,061.72
Review of startup, shutdown, and malfunction plan g	10	1	10	2.8	28	1.4	2.8	$1,530.86
Total (rounded) h					103			$4,900
Assumptions:
a We have assumed that the average number of respondents that will be subject to the rule will be seven (the eight existing respondents, less the one facility that is idle). There will be no additional new sources per year that will become subject to the rule 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 This is a one-time only activity. We assume that EPA will not attend the performance tests that are repeated every two of five years.
d We have assumed that the initial performance test/occurrences per respondent are based on the following: (47.25 indurating furnaces and ore dryer Method 5 PM tests + 101.5 OCH and PH Method 5 PM tests) for a total of 149 Method 5 PM tests for three years. 149 tests/3 years = 50 Method 5 PM tests/year. (50 Method 5 PM tests/year)/(7 plants) = 7 Method 5 PM tests per year per plant.
e We have assumed that each of the fugitive dust emissions control plan will be unchanged.
f We have assumed that it will take 10 hours to review the plan.
g We have assumed that 40 percent of respondents will submit startup, shutdown, and malfunction plan/reports.
h Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: Additional

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,	Annual O&M Costs for One Respondent	Number of Respondents with O&M	Total O&M,
			(B X C)			(E X F)
Scrubbers	$150,000	0	$0	$12,900	7	$90,300
Baghouses	$225,000	0	$0	$19,300	7	$135,100
Contractor Method 5 PM tests1	$0	0	$0	$42,167	7	$295,169
Total2			$0			$521,000
Total Annual Responses
(A)	(B)	(C)	(D)	(E)
			Number of Existing Respondents That Keep Records But Do Not Submit Reports	Total Annual Responses
Information Collection Activity	Number of Respondents	Number of Responses		E=(BxC)+D
Initial notification	0	1	0	0
Compliance extension requests	0	1	0	0
Site-specific test plan	0.56	1	0	0.56
Operation and maintenance plan	0	1	0	0
Fugitive dust emission control plan	0	1	0	0
Site-specific monitoring plan	0	1	0	0
Semiannual compliance reports	7	2	0	14
Petition for alternative monitoring requirements	0	1	0	0
Notification of performance tests	2.8	3	0	8.4
			Total	22.96