Burden Calculation Tables

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Overview

Respondent Burden
Agency Burden
O&M

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Sheet 1: Respondent Burden

Table 1: Annual Respondent Burden and Cost – NESHAP for Inorganic Arsenic Emissions from Primary Copper Smelters (40 CFR Part 61, Subpart O) (Renewal)
Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (AxB)	(D) Respondents per year a	(E) Technical person- hours per year (CxD)	(F) Management person hours per year (Ex0.05)	(G) Clerical person hours per year (Ex0.1)	(H) Total Cost Per year b				New Labor Rates	Old Labor Rates
1. Applications	N/A										Managerial	149.35	108.8
2. Surveys and studies	N/A										Technical	112.98	98.01
3. Acquisition, Installation, and Utilization of Technology and Systems	N/A										Clerical	54.81	46.52
4. Reporting Requirements
A. Familiarization with regulatory requirements	1	1	1	3	3	0.15	0.3	$377.79
B. Required activities	N/A
C. Create information c
i. Grab Samples	1	365	365	3	Tracy Curtis: Added these three subrows under C based on the calculation table in the PDF of the prior SS, but updated to 3 respondents. 1095	54.75	109.5	$137,891.71
ii. Method 108 Analysis	4	12	48	3	144	7.2	14.4	$18,133.70
iii. Monthly Calculation	1	12	12	3	36	1.8	3.6	$4,533.43
D. Gather existing information	See 4E
E. Write report
i. Quarterly report of excess opacity and flow rates d	16	2	32	3	96	4.8	9.6	$12,089.14
ii. Annual report of converter charging rate	16	1	16	3	48	2.4	4.8	$6,044.57
Subtotal for Reporting					1635			$179,070
5. Recordkeeping Requirements
A. Familiarization with regulatory requirements	See 4A
B. Plan activities	N/A
C. Implement activities	See 4C
D. Record data	8	1	8	3	24	1.2	2.4	$3,022.28
E. Time to transmit or disclose information
1. Record Method 108A analysis results	0.5	12	6	3	24	1.2	2.4	$3,022.28			#hrs	2,380	SEE TABLE PG. 15 of SS
2. Monthly measurements	1.5	12	18	3	54	2.7	5.4	$6,800.14			#responses	9
3. Daily log of converter operating mode and daily record of matte charge to converter	0.5	365	182.5	3	547.5	27.375	54.75	$68,945.85			hrs/response	264
F. Time to train personnel	N/A
G. Time for audits	N/A
Subtotal for Recordkeeping					747			$81,791
TOTAL LABOR BURDEN AND COST e					2,380			$261,000
TOTAL ANNUAL COSTS (O&M) e								$1,500
GRAND TOTAL e								$263,000
a It is assumed that there are 3 respondents currently operating in the United States. It is estimated that no additional respondents will become subject to the regulation in the next three years based on information available on the sector.
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 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 The burden to report information includes labor to perform Method 108A analysis once a month; obtain a grab sample daily; labor to reduce opacity and air flow data (Assuming 1 hour per 24 hours of data from each monitoring device); and labor to perform monthly calculations. The burden estimate is based on 1 respondent per year for each activity.
d It is assumed that respondents will only need to submit excess opacity or air flow rate reports twice a year.
e Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 2: Agency Burden

Table 2: Average Annual EPA Burden and Cost – NESHAP for Inorganic Arsenic Emissions from Primary Copper Smelters (40 CFR Part 61, Subpart O) (Renewal)
Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Facilities per year a	(D) Technical person- hours per year (CxD)	(E) Management person hours per year (Ex0.05)	(F) Clerical person hours per year (Ex0.1)	(G) Cost, $			New Labor Rates	Old Labor Rates
Report Review:									Managerial	64.8	37.27
Review of annual report of feed arsenic content	8	1	3	24	1.2	2.4	$1,294.13		Technical	48.08	44.24
ERG/Tracy Curtis: Added this line to account for agency review of quarterly reports. Hourly assumptions are based on similar assumptions from other Part 61 ICRs (e.g., BWON) Review of quarterly excess emissions reports c	2	2	3	12	0.6	1.2	$647.06		Clerical	26.02	23.94
TOTAL BURDEN AND COST d				41			$1,940
a It is assumed that there are 3 respondents currently operating in the United States. It is estimated that no additional respondents will become subject to the regulation in the next three years based on information available on the sector.
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 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 It is assumed that respondents will only need to submit excess opacity or air flow rate reports twice a year.
d Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: O&M

Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A)	(B)	(C)	(D)	(E)	(F)	(G)
Requirement	Capital/Startup Cost for One Respondent	Number of New Respondents	Total Capital/Startup Cost, (B x C x CRF)b	Annual O&M Costs for One Respondent	Number of Respondents with O&M	Total O&M, (E x F)
Method 108A analyses of copper matte samples	$0	0	$0	$500	3	$1,500
Total			$0			$1,500