Burden Calculation Tables

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Overview

Table 1
Table 2
O&M

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Sheet 1: Table 1

Table 1: Annual Respondent Burden and Cost – NESHAP for Iron and Steel Foundries (40 CFR Part 63, Subpart EEEEE) (Renewal)
Burden Item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	Technical person-hours per occurrence	No. of occurrences per respondent per year	Technical person-hours per respondent per year	Respondents per year a	Technical hours per year (E=CxD)	Management hours per year	Clerical hours per year	Total cost per year ($) b
			(C=AxB)			(F=Ex0.05)	(G=Ex0.10)
1. Applications	N/A									Labor Rates
2. Surveys and studies	N/A									Management	$141.06
3. Reporting requirements										Technical	$120.27
a. Familiarize with regulatory requirements c	2	1	2	45	90	5	9	$11,987.10		Clerical	$58.67
b. Required activities d
i. Initial performance tests e	70	3.8	266	0	0	0	0	$0
ii. Follow-up performance tests	70	0.8	56	0	0	0	0	$0
iii. VOC CEMS performance tests e	N/A
iv. Startup, shutdown, malfunction plan	34	1	34	0	0	0	0	$0
v. Operation and maintenance plan	72	1	72	0	0	0	0	$0
vi. Scrap selection/inspection plan d	10	1	10	0	0	0	0	$0
vii. Scrap inspection f	0.5	350	175	45	7,875	394	788	$1,048,871.25
viii. Monthly inspections of capture systems, maintenance of control devices and monitoring systems, and mould vent ignition plan f	2	12	24	18	432	22	43	$57,538.08
c. Create information	See 3B				0	0	0	$0
d. Gather existing information	See 3B				0	0	0	$0
e. Write report					0	0	0	$0
i. Notification of applicability d	2	1	2	0	0	0	0	$0
ii. Notification of construction/reconstruction d	2	1	2	0	0	0	0	$0
iii. Notification of actual startup d	2	1	2	0	0	0	0	$0
iv. Notification of special compliance requirements d	N/A				0	0	0	$0
v. Compliance extension request d	2	1	2	0	0	0	0	$0
vi. Notification of performance test d	2	3.8	7.6	0	0	0	0	$0
vii. Site-specific test plan d	20	3.8	76	0	0	0	0	$0
viii. Notification of CEMS performance evaluation d	60	1	60	0	0	0	0	$0
ix. CEMS QA plan d	40	1	40	0	0	0	0	$0
x. Notification of compliance status d	8	1	8	0	0	0	0	$0
xi. NESHAP waiver application	N/A				0	0	0	$0
xii. Report of performance test	See 3B				0	0	0	$0
xiii. Semiannual compliance reports g	16	2	32	45	1,440	72	144	$191,793.60
xiv. Startup, shutdown, malfunction reports h	4	1	4	1	4	0.2	0.4	$532.76
Subtotal for Reporting Requirements					11,317			$1,310,723
4. Recordkeeping requirements
a. Familiarize with regulatory requirements c	See 3A
b. Plan activities	3	1	3	0	0	0	0	$0
c. Implement activities d	12	1	12	0	0	0	0	$0
d. Develop record system i	3	1	3	0	0	0	0	$0
e. Time to enter information j	1	52	52	45	2,340	117	234	$311,664.60
f. Time to train personnel	3	2	6	0	0	0	0	$0
g. Time to adjust existing ways to comply with previously applicable requirements	N/A				0	0	0	$0
h. Time to transmit information k	0.25	2	0.5	45	23	1	2	$2,996.78
i. Time for audits	N/A				0	0	0	$0.00
Subtotal for Recordkeeping Requirements					2,717			$314,661
Total Labor Burden and Costs (rounded) l					14,000			$1,630,000
Total Capital and O&M Cost (rounded) l								$246,000
Grand Total (rounded) l								$1,880,000
Assumptions:
a We have assumed that the average number of respondents that will be subject to this rule will be 45. There are no new foundries projected during the next three years of this ICR.
b This ICR uses the following labor rates for privately-owned sources: $141.06 for managerial, $120.27 for technical, and $58.67 for clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2019, “Table 2. 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 all respondents will have to familiarize with regulatory requirements each year.
d Only new respondents would have to comply with the initial rule requirements, including notification and performance test for add-on control devices.
e Performance tests are required for particulate matter by Method 5 or total metal HAP by Method 29, for triethylamine by Method 18, and VOHAP by Method 18 or 25A, depending on the emission source. We have assumed that 5 percent of respondents would repeat performance tests due to failure.
f Monitoring and recordkeeping of operations for respondents with add-on control devices include: 1) specific operating parameters for each control device established during the performance test, 2) startup, shutdown, and malfunction of equipment, 3) work practices including an inspection of iron and steel scrap to minimize, to the extent practicable, the amount of organics and HAP metals in the charge materials used by the metal casting department. Eighteen (18) of the 45 facilities must conduct monthly inspections of the capture systems.
g We have assumed that respondents are required to submit semiannual compliance reports that include all the required information concerning deviations from any emissions limitation or operation and maintenance requirements under the NESHAP rule, including those required to be reported under 40 CFR part 70.6(a)(3)(iii)(A) or 40 CFR 71.6(a)(3)(iii)(A).
h We have assumed that one respondent with add-on controls per year will have at least one startup, shutdown or malfunction (SSM) that is not managed according to the SSM plans.
i We have assumed that new respondents would already have the technology and recordkeeping systems in place to monitor daily operations and to comply with existing regulations.
j We have assumed that it will take each respondent one hour 52 times per year to enter information.
k We have assumed that it will take each of the respondents 15 minutes two times per year to transmit information.
l 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 Iron and Steel Foundries (40 CFR Part 63, Subpart EEEEE) (Renewal)
Burden Item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)
	EPA Hours per Occurrence	Number of Occurrences Per Respondent Per Year	EPA Hours Per Respondent Per Year (C=AxB)	Number of Respondents Per Year a	Technical Hours Per Year (E=CXD)	Management Hours Per Year (F=Ex0.05)	Clerical Hours Per Year (G=Ex0.1)	Total Costs, $ b
1. Applications
2. Surveys and Studies
3. Reporting Requirements
a. Initial performance test	40	1	40	0	0	0	0	$0		Labor Rates
b. Repeat performance – retesting	40	1	40	0	0	0	0	$0		Management	$66.62
c. Report review c										Technical	$49.44
d. Notification of construction/reconstruction	N/A									Clerical	$26.75
e. Notification of actual startup	N/A
f. Notification of special compliance requirements	N/A
g. Notification of applicability	2	1	2	0	0	0	0	$0
h. Notification of initial performance test	2	1	2	0	0	0	0	$0
i. Notification of CEMS performance evaluation	2	1	2	0	0	0	0	$0
j. CEMS QA plan	2	1	2	0	0	0	0	$0
k. Notification of compliance status	4	1	4	0	0	0	0	$0
l. Site-specific test plan	2	1	2	0	0	0	0	$0
m. Scrap selection/inspection plan	4	1	4	0	0	0	0	$0
n. Repeat performance test report	2	1	2	0	0	0	0	$0
o. Semiannual compliance reports d	4	2	8	45	360	18	36	$19,960.56
p. NESHAP waiver application	4	1	4	0	0	0	0	$0
q. Compliance extension request	4	1	4	0	0	0	0	$0
r. Scrap inspections	N/A
s. Emergency startup, shutdown, and malfunction report e	4	1	4	1	4	0.2	0.4	$221.78
TOTAL (rounded) f					419			$20,200
Assumptions:
a We have assumed that the average number of respondents that will be subject to this rule will be 45. There will be no new foundries projected during the next three years of this ICR.
b This ICR uses the following labor rates: $66.62 for managerial, $49.44 for technical, and $26.75 for clerical labor. These rates are from the Office of Personnel Management (OPM), 2019 General Schedule, which excludes locality rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees.
c Only new respondents would have to comply with the initial rule requirements, including notification and performance test for add-on control devices.
d We have assumed that respondents are required to submit semiannual compliance reports
e We have assumed that one respondent with add-on controls per year will have one startup, shutdown or malfunction (SSM) that is not managed according to the SSM plans.
f Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: O&M

Total Annual Responses
(A)	(B)	(C)	(D)	(E)
Information Collection Activity	Number of Respondents	Number of Responses	Number of Existing Respondents That Keep Records But Do Not Submit Reports	Total Annual Responses E=(BxC)+D
Initial notification	0	0	0	0
Semiannual compliance reports	45	2	0	90
Startup, shutdown, malfunction reports	1	1	0	1		hours	14,000
			Total	91		hr/response	154
Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
Year	(A)	(B)	(C)	(D)	(E)
	Number of New Respondents a	Number of Existing Respondents	Number of Existing Respondents that keep records but do not submit reports	Number of Existing Respondents That Are Also New Respondents	Number of Respondents (E=A+B+C-D)
1	0	45	0	0	45
2	0	45	0	0	45
3	0	45	0	0	45
Average	0	45			45
a New respondents include sources with constructed, reconstructed and modified affected facilities.
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 (E X F)
Leak detectors a	$9,000	0	$0	$1,470	45	$66,150
Flow rate monitors b	$7,500	0	$0	$2,000	45	$90,000
pH monitor b	$7,500	0	$0	$2,000	27	$54,000
Pressure drop b	$7,500	0	$0	$2,000	18	$36,000
VOC CEM	$100,000	0	$0	$10,000	0	$0
Total c			$0			$246,000
a We assume 3 baghouses per respondent and O&M costs of $500 per year.
b We assume pressure drop and scrubber liquid flow rate monitors at 18 venturi (PM) web scrubbers; and flow rate and pH monitors for 27 acid/wet scrubbing systems. We assume a yearly O&M cost of $2,000 for each parametric monitoring system.
c Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.